MISSILE DEFENSE AGENCY

ADMINISTRATIVE RECORD FOR MISSILE 

DEFENSE AGENCY (MDA) PROPOSED CATEGORICAL

EXCLUSIONS (CATEXs) UNDER THE NATIONAL 

ENVIRONMENTAL POLICY ACT (NEPA)

Distribution Statement A: Approved for public release; distribution is unlimited.

October 2013

Office of Primary Responsibility:

Facilities, Military Construction and Environmental Management (MDA/DPF)

Approved for Public Release 13-MDA-7375 (3 July 13)
TABLE OF CONTENTS

I. DEVELOPMENT PROCESS............................................................................................. 1

II. CATEX LIST...................................................................................................................... 3

III. ADMINISTRATIVE RECORD FOR MDA CATEXS ..................................................... 7

B-1. Normal personnel, fiscal or budgeting, and administrative activities and decisions 

including those involving military and civilian personnel (for example, recruiting, 

processing, paying, and record keeping)................................................................. 7

B-2. Preparing, revising, or adopting regulations, instructions, directives, or guidance 

documents including those that implement without substantial change the 

regulations, instructions, directives, or guidance documents from higher 

headquarters or other Federal agencies................................................................... 8

B-3. Decreases, increases, relocation and realignment of personnel into existing 

Federally-owned or commercially-leased space that does not involve a substantial 

change affecting the supporting infrastructure or use of space (e.g., no increase in 

traffic beyond the capacity of the supporting network to accommodate such an 

increase). ............................................................................................................... 10

B-4. Routine procurement of goods and services conducted in accordance with 

applicable procurement regulations, Executive orders (EO), and policies to 

support operations and infrastructure, including routine utility services and 

contracts. ............................................................................................................... 13

B-5. Administrative study efforts involving no commitment of resources other than 

personnel and funding allocations. If any of these study efforts result in proposals 

for further action, those proposals must be considered separately by an 

appropriate CATEX or NEPA analysis ................................................................ 15

B-6. Studies, monitoring, data and sample collection, and information gathering that 

involve no permanent physical change to the environment. If any of these 

activities result in proposals for further action, those proposals must be 

consideredby an appropriate CATEX or NEPA analysis..................................... 20

B-7. Sampling, well drilling and installation, analytical testing, site preparation and 

minimally intrusive physical testing. These activities could involve minor 

clearing and grubbing or movement of heavy equipment such as drill rigs. If any 

of these actions result in proposals for further actions, those proposals must be 

considered by an appropriate CATEX or NEPA analysis.................................... 26

B-8. Immediate responses to the release or discharge of oil or hazardous materials in 

accordance with an approved Spill Prevention, Control and Countermeasure 

(SPCC) Plan or Spill Contingency Plan, or that is otherwise consistent with the 

requirements of the EPA National Contingency Plan........................................... 33

i October 2013
B-9. Temporary use of transportable power generators or operational support 

equipment when located in a previously disturbed area and when operated in 

compliance with applicable regulatory requirements. .......................................... 37

B-10. Routine movement, handling, use and distribution of materials, including 

hazardous materials or wastes that are moved, handled, or distributed in 

accordance with applicable regulations, such as Resource Conservation and 

Recovery Act (RCRA), Occupational Safety and Health Administration (OSHA) 

and Hazardous Materials Transportation Act (HMTA)........................................ 49

B-11. Routine movement of mobile test assets (such as ships, aircraft, mobile sensors, 

telemetry, etc.) for routine missile defense test and evaluation, for repair, overhaul 

or maintenance, or for home port reassignments where no new support facilities 

are required. .......................................................................................................... 58

B-12. Activities and operations to be conducted in an existing non-historic structure 

which are within the scope of and are compatible with the present functional use 

of the building, will not result in a substantial increase in waste discharged to the 

environment, will not result in substantially different waste discharges from 

current or previous activities, and emissions will remain within established permit 

limits, if any. ......................................................................................................... 67

B-13. Acquisition, installation, modification, routine repair and replacement, and 

operation of utility (e.g., water, sewer, and electrical) and communication 

systems, mobile antennas, data processing cable, and similar electronic equipment 

that use existing rights-of-way, easements, distribution systems, facilities, or 

previously disturbed land...................................................................................... 73

B-14. Acquisition, installation or minor relocation, operation and maintenance or 

evaluation of physical security devices or controls to protect human or animal life 

and to enhance the physical security of existing critical assets in compliance with 

applicable Federal, tribal, state and local requirements to protect the environment

............................................................................................................................... 85

B-15. Maintenance of archaeological, historical, and endangered or threatened species 

avoidance markers, fencing, and signs. ................................................................ 94

B-16. Road or trail construction and repair on existing rights-of-ways or in previously 

disturbed areas which do not result in a change in functional use. Runoff, erosion, 

and sedimentation are controlled through implementation of best management 

practices (BMP) .................................................................................................... 97

B-17. Routine repair and maintenance of buildings, vessels, aircraft, grounds, and other 

facilities and equipment which do not result in a change in functional use or a 

significant impact on a historically significant element or setting ..................... 102

B-18. New construction or equipment installation or alterations (interior and exterior) to 

or construction of an addition to an existing structure that is similar to existing 

land use if the area to be disturbed has no more than 5.0 cumulative acres of new 

surface disturbance.............................................................................................. 109

ii October 2013
B-19. Demolition of non-historic buildings, structures, or other improvements and 

repairs that result in disposal of debris there-from, or removal of a part thereof for 

disposal, in accordance with applicable regulations, including those regulations 

applying to removal of asbestos containing materials (ACM), polychlorinated 

biphenyls (PCBs), lead-based paint (LBP), and other special hazard items....... 123

B-20. Research, testing, and operations conducted at existing facilities and plants or 

laboratories (including contractor-operated laboratories and plants) and in 

compliance with all applicable safety, environmental and natural conservation 

laws. .................................................................................................................... 132

B-21. Routine installation and use of radars, telemetry systems, communications 

equipment, and other essentially similar facilities and equipment within a launch 

facility, mobile platform, military installation, training area, or previously 

disturbed area that conform to current American National Standards 

Institute/Institute of Electrical and Electronics Engineers (ANSI/IEEE) guidelines 

for maximum permissible exposure to electromagnetic fields........................... 142

IV. ACRONYMS AND ABBREVIATIONS....................................................................... 158

V. QUALIFICATION OF PREPARERS............................................................................ 162

LIST OF TABLES

Table B-5.1 Comparative Analysis of MDA Proposed CATEX B-5 to Other Agency 

CATEXs................................................................................................................ 18

Table B-6.1 Comparative Analysis of MDA Proposed CATEX B-6 to Other Agency 

CATEXs................................................................................................................ 24

Table B-7.1 Comparative Analysis of MDA Proposed CATEX B-7 to Other Agency 

CATEXs................................................................................................................ 31

Table B-8.1 Comparative Analysis of MDA Proposed CATEX B-8 to Other Agency 

CATEXs................................................................................................................ 35

Table B-9.1 Comparative Analysis of MDA Proposed CATEX B-9 to Other Agency 

CATEXs................................................................................................................ 43

Table B-9.2 Comparative Analysis of MDA Proposed CATEX B-9 to MDA 

Environmental Reviews........................................................................................ 45

Table B-10.1 Comparative Analysis of MDA Proposed CATEX B-10 to Other Agency 

CATEXs................................................................................................................ 54

Table B-10.2 Comparative Analysis of MDA Proposed CATEX B-10 to MDA 

Environmental Reviews........................................................................................ 56

Table B-11.1 Comparative Analysis of MDA Proposed CATEX B-11 to Other Agency 

CATEXs................................................................................................................ 63

Table B-11.2 Comparative Analysis of MDA Proposed CATEX B-11 to MDA 

Environmental Reviews........................................................................................ 65

Table B-12.1 Comparative Analysis of MDA Proposed CATEX B-12 to Other Agency 

CATEXs................................................................................................................ 71

Table B-12.2 Comparative Analysis of MDA Proposed CATEX B-12 to MDA 

Environmental Reviews........................................................................................ 72

iii October 2013
Table B-13.1 Comparative Analysis of MDA Proposed CATEX B-13 to Other Agency 

CATEXs................................................................................................................ 81

Table B-13.2 Comparative Analysis of MDA Proposed CATEX B-13 to MDA 

Environmental Reviews........................................................................................ 83

Table B-14.1 Comparative Analysis of MDA Proposed CATEX B-14 to Other Agency 

CATEXs................................................................................................................ 90

Table B-14.2 Comparative Analysis of MDA Proposed CATEX B-14 to MDA 

Environmental Reviews........................................................................................ 92

Table B-15.1 Comparative Analysis of MDA Proposed CATEX B-15 to Other Agency 

CATEXs................................................................................................................ 96

Table B-16.1 Comparative Analysis of MDA Proposed CATEX B-16 to Other Agency 

CATEXs...............................................................................................................100

Table B-17.1 Comparative Analysis of MDA Proposed CATEX B-17 to Other Agency 

CATEXs...............................................................................................................106

Table B-17.2 Comparative Analysis of MDA Proposed CATEX B-17 to MDA 

Environmental Reviews.......................................................................................108

Table B-18.1 Comparative Analysis of MDA Proposed CATEX B-18 to Other Agency 

CATEXs...............................................................................................................119

Table B-18.2 Comparative Analysis of MDA Proposed CATEX B-18 to MDA 

Environmental Reviews.......................................................................................121

Table B-19.1 Comparative Analysis of MDA Proposed CATEX B-19 to Other Agency 

CATEXs...............................................................................................................128

Table B-19.2 Comparative Analysis of MDA Proposed CATEX B-19 to MDA 

Environmental Reviews.......................................................................................130

Table B-20.1 Comparative Analysis of MDA Proposed CATEX B-20 to Other Agency 

CATEXs...............................................................................................................139

Table B-20.2 Comparative Analysis of MDA Proposed CATEX B-20 to MDA 

Environmental Reviews.......................................................................................141

Table B-21.1 Comparative Analysis of MDA Proposed CATEX B-21 to Other Agency 

CATEXs...............................................................................................................153

Table B-21.2 Comparative Analysis of MDA Proposed CATEX B-21 to MDA 

Environmental Reviews.......................................................................................155

iv October 2013
ADMINISTRATIVE RECORD (AR) FOR THE MISSILE DEFENSE 

AGENCY (MDA) PROPOSED CATEGORICAL EXCLUSIONS 

(CATEXs) UNDER THE NATIONAL ENVIRONMENTAL 

POLICY ACT (NEPA)

I. DEVELOPMENT PROCESS

MDA legal and environmental professionals, including four MDA civilians and five independent 

contractors, worked together as a Team to develop the MDA CATEXs and supporting 

administrative record. The environmental professionals on the Team were environmental 

practitioners with numerous years of planning and compliance experience, including preparing

environmental documents such as assessments, impact statements, findings of no significant 

impact, and records of decision. The Team also included a legal practitioner with advanced 

education and experience advising Federal agency managers on environmental planning and 

compliance responsibilities. All of these professionals have significant experience developing 

and executing NEPA strategies for MDA and other agencies. Resumes for Team members are at 

the end of the AR.

To determine the types of MDA activities to consider for categorical exclusions, the Team

reviewed all MDA NEPA documents and mitigation and monitoring reports to determine if 

MDA activities resulted in significant environmental impacts on the various military Service 

installations/ranges or other properties where these activities took place. The Team determined 

no significant adverse environmental impacts resulting from our activities were ever reported or 

observed through MDA’s monitoring or host installation environmental staff observation. We 

also reviewed and characterized the types of activities we conduct for CATEXs being proposed, 

how those activities are conducted, and how often those activities are conducted to facilitate 

benchmarking and comparing similar activities conducted by the Services and other federal 

agencies.

The MDA NEPA implementing procedures define four screening criteria that must be met before 

a CATEX may be used and seven extraordinary circumstances that preclude using a CATEX. 

Some CATEXs require documentation using a record of environmental consideration (REC) the 

proposed action qualifies as a CATEX and screening criteria are met (Appendix C of 

Implementing Procedures). The MDA RECs are signed statements, submitted with project 

documentation briefly documenting a MDA action has received environmental review. The 

REC will briefly describe the proposed action and timeframe, identify the proponent and 

approving official(s), and clearly show how a particular action qualifies for a CATEX. When 

used to support a CATEX, the REC will address our use of screening criteria to ensure no 

extraordinary circumstances exist.

Each proposed CATEX was developed from existing CATEXs adopted by the Army, Navy, and 

Air Force (USAF), and other Federal agencies. The majority of MDA actions occur on Service

(or host) installations or ranges. We have extensive experience using the respective Services’ 

CATEXs for minor actions occurring on the host installation or range. The frequency of our 

actions and activities are not expected to increase from that of previous years as a result of the

1 October 2013
MDA developing our own CATEXs. We also conducted an extensive review of other Federal 

agency CATEXs. Each proposed CATEX was reviewed and deliberated in concept, coverage, 

applicability and wording. We carefully crafted each CATEX with the goals of increasing

administrative efficiency in NEPA compliance and avoiding misuse of the CATEXs that could 

lead to non-compliance with NEPA requirements. We determined the attached categorical 

exclusions met both objectives.

The Team considered the potential environmental impacts of the activities covered by these 

CATEXs and, based upon previous analyses and experience with these types of activities since 

the mid 1990's, determined these activities will not individually or cumulatively create a 

significant impact on the environment and do not require additional NEPA analysis and 

documentation unless extraordinary circumstances exist (40 C.F.R. § 1508.4). This 

determination is further supported by the MDA’s analysis and conclusions documented in the

Ballistic Missile Defense System (BMDS) Programmatic Environmental Impact Statement 

(PEIS), 2007. 

Once established, the MDA will satisfy NEPA when using these CATEXs by determining 

whether a proposed action falls entirely within one or more CATEXs’ description of the 

activities and by reviewing the proposal to determine whether extraordinary circumstances exist. 

In the event extraordinary circumstances exist, an environmental assessment or an environmental 

impact statement will be prepared before proceeding with the proposed action. 

The Team spent substantial time and effort deliberating over and drafting these CATEXs. We 

consulted with the Council on Environmental Quality (CEQ) to ensure the implementing 

procedures and all CATEXs conform to the requirements of NEPA. We took great care to 

ensure the CATEXs were supported by the administrative record. 

A summary of information collected and relied upon by the Team in formulating and deciding 

the extent and limitations of the CATEXs is provided below. We envision this information will 

help interested parties understand the basis and rationale behind each CATEX. This information 

is not meant to provide an exhaustive list of factors relied upon during development of the 

CATEXs, but rather, to detail the basis upon which each CATEX was established. 

Actions that are categorically excluded in the absence of unique circumstances are listed below. 

2 October 2013
II. CATEX LIST

B-1. Normal personnel, fiscal or budgeting, and administrative activities and decisions 

including those involving military and civilian personnel (for example, recruiting, 

processing, paying, and record keeping). 

B-2. Preparing, revising, or adopting regulations, instructions, directives, or guidance 

documents including those that implement without substantial change the regulations, 

instructions, directives, or guidance documents from higher headquarters or other 

Federal agencies. 

B-3. Decreases, increases, relocation and realignment of personnel into existing 

Federally-owned or commercially-leased space that does not involve a substantial 

change affecting the supporting infrastructure or use of space (e.g., no increase in 

traffic beyond the capacity of the supporting network to accommodate such an 

increase).

B-4. Routine procurement of goods and services conducted in accordance with applicable 

procurement regulations, Executive orders (EO), and policies to support operations and 

infrastructure, including routine utility services and contracts.

B-5. Administrative study efforts involving no commitment of resources other than 

personnel and funding allocations. If any of these study efforts result in proposals for 

further action, those proposals must be considered separately by an appropriate CATEX or 

NEPA analysis. Examples include, but are not limited to: studies conducted to further 

administrative, personnel-related, architectural, engineering, safety, security, siting, 

and facility audit activities. 

B-6. Studies, monitoring, data and sample collection, and information gathering that 

involve no permanent physical change to the environment. If any of these activities

result in proposals for further action, those proposals must be considered by an 

appropriate CATEX or NEPA analysis. Examples include, but are not limited to:

a. Surveys for threatened and endangered species, wildlife and wildlife habitat, 

historic properties and archeological sites; wetland delineations; minimal water, 

air, waste; material and soil sampling (e.g., grab samples);

b. Vulnerability, risk, and structural integrity assessments of infrastructure;

c. Environmental Baseline Surveys or Environmental Condition of Property 

Surveys; and

d. Topographical surveying and mapping that does not require cutting and/or 

removal of trees.

B-7. Sampling, well drilling and installation, analytical testing, site preparation and 

minimally intrusive physical testing. These activities could involve minor clearing, 

grubbing or movement of heavy equipment such as drill rigs. If any of these actions 

result in proposals for further actions, those proposals must be considered by an 

appropriate CATEX or NEPA analysis. Examples include, but are not limited to:

3 October 2013
a. Sampling for asbestos containing materials (ACM), polychlorinated biphenyls

(PCB), lead-based paint (LBP);

b. Topographical surveys and surveys for unexploded ordnance; 

c. Minimally-intrusive geological, geophysical surveys, geo-technical activities, and 

seismic studies;

d. Minimally-intrusive sampling to determine if hazardous wastes, contaminants, 

pollutants, or special hazards are present; or 

e. Ground-water monitoring wells, subsurface soil sampling and soil borings.

(REC required.)

B-8. Immediate responses to the release or discharge of oil or hazardous materials in 

accordance with an approved Spill Prevention, Control and Countermeasure (SPCC)

Plan or Spill Contingency Plan, or that is otherwise consistent with the requirements of 

the EPA National Contingency Plan.

B-9. Temporary use of transportable power generators or operational support 

equipment when located in a previously disturbed area and when operated in 

compliance with applicable regulatory requirements.

B-10. Routine movement, handling, use and distribution of materials, including hazardous 

materials or wastes that are moved, handled, or distributed in accordance with 

applicable regulations, such as Resource Conservation and Recovery Act (RCRA), 

Occupational Safety and Health Administration (OSHA) and Hazardous Materials 

Transportation Act (HMTA).

B-11. Routine movement of mobile test assets (such as ships, aircraft, mobile sensors, 

telemetry, etc.) for routine missile defense test and evaluation, for repair, overhaul or 

maintenance, or for home port reassignments where no new support facilities are 

required.

B-12. Activities and operations to be conducted in an existing non-historic structure which 

are within the scope of and are compatible with the present functional use of the 

building, will not result in a substantial increase in waste discharged to the 

environment, will not result in substantially different waste discharges from current or 

previous activities, and emissions will remain within established permit limits, if any. 

B-13. Acquisition, installation, modification, routine repair and replacement, and 

operation of utility (e.g., water, sewer, and electrical) and communication systems, 

mobile antennas, data processing cable, and similar electronic equipment that use 

existing rights-of-way, easements, distribution systems, facilities, or previously 

disturbed land. (REC required.)

B-14. Acquisition, installation or minor relocation, operation and maintenance or 

evaluation of physical security devices or controls to protect human or animal life and 

to enhance the physical security of existing critical assets in compliance with applicable 

4 October 2013
Federal, tribal, state and local requirements to protect the environment. Examples 

include, but are not limited to:

a. Motion detection systems; 

b. Raptor electrocution prevention devices;

c. Lighting;

d. Remote video surveillance systems;

e. Access controls; and

f. Physical barriers, fences, grating, on or adjacent to existing facilities. 

(REC required.)

B-15. Maintenance of archaeological, historical, and endangered or threatened species 

avoidance markers, fencing, and signs.

B-16. Road or trail construction and repair on existing rights-of-ways or in previously 

disturbed areas which do not result in a change in functional use. Runoff, erosion, and 

sedimentation controlled through implementation of best management practices

(BMP). (REC required.)

B-17. Routine repair and maintenance of buildings, vessels, aircraft, grounds, and other 

facilities and equipment which do not result in a change in functional use or a 

significant impact on a historically significant element or setting. Examples include, but 

are not limited to: repair of roofs, doors, windows, or fixtures, localized pest 

management, and minor erosion control measures. 

B-18. New construction or equipment installation or alterations (interior and exterior) to 

or construction of an addition to an existing structure that is similar to existing land use 

if the area to be disturbed has no more than 5.0 cumulative acres of new surface 

disturbance. The following conditions must be met:

a. The structure and proposed use are compatible with applicable Federal, tribal, 

state and local planning and zoning standards;

b. The site and scale of construction or improvement is consistent with those of 

existing, adjacent, or nearby buildings, and;

c. The construction or improvement will not result in uses that exceed existing 

support infrastructure capacities (roads, sewer, water, parking, etc.). 

This does not include construction of facilities for the transportation, distribution, use, 

storage, treatment, and disposal of solid waste or hazardous waste. (REC required.)

B-19. Demolition of non-historic buildings, structures, or other improvements and repairs 

that result in disposal of debris there-from, or removal of a part thereof for disposal, in 

accordance with applicable regulations, including those regulations applying to removal 

of asbestos containing materials (ACM), polychlorinated biphenyls (PCBs), lead-based 

paint (LBP), and other special hazard items. (REC required.)

B-20. Research, testing, and operations conducted at existing facilities and plants or 

laboratories (including contractor-operated laboratories and plants) and in compliance 

with all applicable safety, environmental and natural conservation laws. Examples 

include, but are not limited to: wind tunnels, high energy lasers, remote sensing 

5 October 2013
instruments, vacuum chambers, high altitude simulator facilities, and propellant testing 

facilities. 

B-21. Routine installation and use of radars, telemetry systems, communications 

equipment, and other essentially similar facilities and equipment within a launch 

facility, mobile platform, military installation, training area, or previously disturbed 

area that conform to current American National Standards Institute/Institute of 

Electrical and Electronics Engineers (ANSI/IEEE) guidelines for maximum permissible 

exposure to electromagnetic fields. (REC required.)

6 October 2013
III. ADMINISTRATIVE RECORD FOR MDA CATEXS

B-1. Normal personnel, fiscal or budgeting, and administrative activities and decisions 

including those involving military and civilian personnel (for example, recruiting, 

processing, paying, and record keeping).

The actions contemplated by this CATEX are a variety of administrative activities having no 

potential for significant environmental impacts. This CATEX is supported by long-standing 

practices and use of similar CATEXs by the Services and other Federal agencies. MDA found 

that actions of a similar nature, scope, and intensity were performed throughout the Federal 

government without significant environmental impacts. MDA has been conducting similar

administrative type activities for over 20 years and they are conducted primarily in an office 

setting and would not impact the environment.

Based upon the extensive history of the application of similar CATEXs by the Services and other 

Federal agencies and the absence of extraordinary circumstances associated with their 

application, this CATEX is determined to be applicable to MDA projects. MDA, being a 

Department of Defense (DoD) component, conducts administrative, fiscal, and personnel 

activities in a similar manner as the Services. 

Comparable Agency Categorical Exclusions and Administrative Records

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(b)(5) Normal personnel, fiscal, and administrative activities involving military and 

civilian personnel (recruiting, processing, paying, and records keeping).

U.S. Navy

Reference: OPNAVINST 5090.1C, Categorical Exclusions

(1) Routine fiscal and administrative activities, including administration of contracts.

(10) Routine personnel actions.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.4. Normal personnel, fiscal or budgeting, and administrative activities and 

decisions including those involving military and civilian personnel (for example, 

recruiting, processing, paying, and records keeping).

7 October 2013
U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(1) Routine personnel, fiscal, and administrative activities, actions, procedures, and 

policies which clearly do not have any environmental impacts, such as military and 

civilian personnel recruiting, processing, paying, and record keeping.

Federal Emergency Management Agency 

Reference: 44 CFR 10.8 (d) (2)

(i) Administrative actions such as personnel actions, travel, procurement of supplies, etc., 

in support of normal day-to-day activities and disaster related activities

MDA Environmental Reviews

Reference: US AF Form 813 (AF 813) AF Permit to Missile Defense Agency for Use 

of Administrative Space at 10441 Kuter Avenue, May 2008. Qualifies for USAF

CATEX A2.3.4. 

The proposed action was to initiate a real estate transaction to permit authorized use of 

approximately 6,000 square feet of space at 10441 Kuter Avenue at Elmendorf Air Force 

Base (AFB).

B-2. Preparing, revising, or adopting regulations, instructions, directives, or guidance 

documents including those that implement without substantial change the regulations, 

instructions, directives, or guidance documents from higher headquarters or other 

Federal agencies.

The actions contemplated by this CATEX are a variety of administrative activities having no 

potential for significant environmental impacts. This CATEX is supported by long-standing 

practice and use of similar CATEXs by the Services and other Federal agencies. The Team

found that actions of a similar nature, scope, and intensity were performed throughout the 

Federal government without significant environmental impacts. MDA has been conducting 

these administrative type activities for over 20 years. They are conducted primarily in an office 

setting and would not impact the environment.

Based upon the extensive history of the application of similar CATEXs by the Services and other 

Federal agencies and the absence of extraordinary circumstances associated with their 

application, this CATEX is determined to be applicable to MDA projects. MDA, being a DoD 

component, conducts regulations management and guidance document activities in a similar

manner as the Services. 

In addition, MDA recognized other Federal agencies, with very few limitations, must meet the 

same requirements to protect the environment. The Team determined the characteristics of the 

activities at MDA were no different from those performed by other Federal agencies. 

8 October 2013
Comparable Agency Categorical Exclusions and Administrative Records

U.S. Army 

Reference: 32 CFR Part 651, Appendix B Categorical Exclusions

(b)(3) Preparation of regulations, procedures, manuals, and other guidance documents 

that implement, without substantive change, the applicable Headquarters Department of 

the Army or other federal agency regulations, procedures, manuals, and other guidance 

documents that have been environmentally evaluated (subject to previous NEPA review).

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(5) Issuance or modification of administrative procedures, regulations, directives, 

manuals, or policy.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.5. Preparing, revising, or adopting regulations, instructions, directives, or guidance 

documents that do not, themselves, result in an action being taken.

A2.3.6. Preparing, revising, or adopting regulations, instructions, directives, or guidance 

documents that implement (without substantial change) the regulations, instructions, 

directives, or guidance documents from higher headquarters or other Federal agencies 

with superior subject matter jurisdiction.

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(33) Preparation of guidance documents that implement, without substantive change, the 

applicable Commandant Instruction or other Federal agency regulations, procedures, 

manuals, and other guidance documents.

Federal Emergency Management Agency 

Reference: 44 CFR 10.8 (d) (2)

(ii) Preparation, revision, and adoption of regulations, directives, manuals, and other 

guidance documents related to actions that qualify for categorical exclusions.

9 October 2013
B-3. Decreases, increases, relocation and realignment of personnel into existing 

Federally-owned or commercially-leased space that does not involve a substantial 

change affecting the supporting infrastructure or use of space (e.g., no increase in 

traffic beyond the capacity of the supporting network to accommodate such an 

increase). 

The Team found actions of a similar nature, scope and intensity throughout the Federal 

government without significant environmental impacts. Such actions include a variety of 

internal administrative activities, as well as activities involving the physical relocation of 

personnel and equipment. For example, MDA has significant experience increasing and 

decreasing personnel (some through the Base Realignment and Closure (BRAC) process) and 

routinely relocating personnel into several locations at host installations; the Huntsville, AL area; 

Colorado Springs, CO; Dahlgren, VA; and the National Capital Region (NCR). Environmental 

Assessments (EAs) and Environmental Impact Statements (EISs) were prepared for large 

relocations and realignments as described further below. These activities have not resulted in 

significant environmental impacts.

However, the Team was aware that physical relocations of personnel and equipment could 

involve a variety of associated activities, some of which could potentially impact the human 

environment. To clearly demonstrate those activities were beyond the scope of this CATEX, the 

Team included language limiting its scope to actions which would not result in exceeding the 

infrastructure capacity or changing the general use of space involved by that activity.

The Team cited the example of an increase in vehicular traffic beyond the capacity of the 

supporting road network to accommodate that increase. This example was intended to exemplify 

a reduction, realignment or relocation that would not be encompassed by this CATEX due to 

extraordinary circumstances that may result in the activity having significant environmental 

effects. The Team provided this example to ensure future users of this CATEX would be alerted 

to the potential for such indirect impacts when contemplating using this CATEX. 

The Team also noted numerous other Federal agencies have CATEXs for similar activities that 

are sufficiently descriptive of the activity as to establish for the Team that those activities were 

similar in nature, scope, and impact on the human environment as those performed by MDA. In 

addition, the Team recognized all Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment. The Team determined the characteristics of 

MDA activities were no different from those performed by other Federal agencies. All Federal 

agencies routinely experience increases, decreases, relocation and realignment of personnel into 

existing Federally-owned or commercially leased space, and have done so for many years. The 

characteristics of the action, i.e., movement of Federal agency personnel into and out of existing 

office space and are accomplished in much the same manner throughout the Federal 

Government. The frequency of these actions at MDA is no greater than other DoD agencies, and 

are estimated to be less as a whole especially given the relatively small size of MDA. The 

context, standards, and protocols governing these movements are similar throughout Federal 

Government and the General Services Administration (GSA) is often involved. These activities 

have been occurring for many years and no individual or cumulative significant impacts on the 

10 October 2013
human environment have been reported. For the past 20 years, MDA has been using existing 

Military Service CATEXs for these activities and have found their use appropriate.

Comparable Agency Categorical Exclusions and Administrative Records

U.S. Army 

Reference: 32CFR Part 651, Appendix B, Categorical Exclusions

(b)(12) Reductions and realignments of civilian and/or military personnel that: fall below 

the thresholds for reportable actions as prescribed by statute (10 United State Code 

(U.S.C.) 2687) and do not involve related activities such as construction, renovation, or 

demolition activities that would otherwise require an EA or an EIS to implement (REC 

required). This includes reorganizations and reassignments with no changes in force 

structure, unit redesignations, and routine administrative reorganizations and 

consolidations (REC required).

(b)(14) Relocation of personnel into existing federally-owned (or state-owned in the case 

of Army National Guard) or commercially-leased space, which does not involve a 

substantial change in the supporting infrastructure (for example, an increase in vehicular 

traffic beyond the capacity of the supporting road network to accommodate such an 

increase is an example of substantial change) (REC required).

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(39) Relocation of personnel into existing federally-owned or commercially leased space 

that does not involve a substantial change affecting the supporting infrastructure (e.g., no

increase in vehicular traffic beyond the capacity of the supporting road network to 

accommodate such an increase).

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.21. Routine personnel decreases and increases, including work force conversion to 

either on-base contractor operation or to military operation from contractor operation 

(excluding base closure and realignment actions which are subject to congressional 

reporting under 10 U.S.C. 2687).

U.S. Department of Homeland Security 

Reference: Directive 023-01, Environmental Planning Program

Reductions, realignments, or relocation of personnel that do not result in exceeding the 

infrastructure capacity or changing the use of space. An example of a substantial change 

in use of supporting infrastructure would be an increase in vehicular traffic beyond the 

capacity of the supporting road network to accommodate such an increase.

11 October 2013
Reference: Environmental Assessment for Base Realignment and Closure, 

Installation Support, and Associated Future Master Planning Actions at Redstone 

Arsenal, Alabama, 2006, resulting in a Finding of No Significant Impact (FONSI)

Note: This Army EA included MDA’s movement of personnel from various locations to 

Huntsville, AL. MDA typically would not use a CATEX for this large of a relocation of 

personnel. However, the EA demonstrates that conducting activities contemplated in this 

CATEX of this magnitude did not result in a significant impact to the environment, thus 

these actions on a smaller level would not be expected to result in significant 

environmental impacts as long as no extraordinary circumstances exist. 

This EA considered the environmental impacts involving BRAC-directed actions, 

including the construction of Phase III and IV of the Von Braun Complex for MDA and 

relocating MDA functions and personnel from leased facilities in Arlington, VA, Falls 

Church, VA, and Huntsville, AL to Redstone Arsenal. The Von Braun Complex would 

be expanded to provide administrative space and specialized computer laboratories. 

Approximately 3,500 personnel were expected to be relocated into Von Braun III and IV 

upon construction completion.

Thirteen environmental resource areas were evaluated and no potential impacts were 

classified as significant based on the significance criteria. 

Von Braun IV is currently being constructed and is expected to be complete in FY 2016. 

A recent review of construction activities and relocation of personnel into Von Braun IV 

determined no additional analysis NEPA analysis was needed and no significant 

environmental impacts would occur. 

Missile Defense Agency Environmental Reviews

Reference: Environmental Impact Statement for Implementation of 2005 Base 

Realignment and Closure (BRAC) Recommendations and Related Army Actions at 

Fort Belvoir, Virginia, 2007

The Army proposed two actions concerning Fort Belvoir, VA: Revising the Fort Belvoir 

land use plan, and realigning units, agencies, and activities to Fort Belvoir. Construction 

and renovation of facilities would be required to accommodate the larger workforce

(approximately 22,000). Six major entities would relocate to Fort Belvoir, including 

approximately 292 personnel from MDA, Headquarters Command Center. Construction

and renovation of facilities to support additional personnel at Fort Belvoir would entail 

20 separate facilities projects totaling about 6.2 million square feet of built space and 

about 7 million square feet of parking structures. One of those facilities would be for a 

MDA facility at 107,000 square feet on approximately 1.3 acres. MDA’s small footprint 

compared to the overall project (107,000 square feet vs. 6.3 million square feet) would 

have a minimal impact to the environment. As would be expected from such a large 

project, adverse effects on the transportation system would be expected. However, 

proposed road improvements could mitigate the effects of the proposed action. All other 

impacts to the environment were expected to be minor.

12 October 2013
Reference: Record of Categorical Exclusion (RCE) Re-engineering of Missile Defense 

Agency AEGIS Ballistic Missile Defense (Relocation of MDA personnel to Dahlgren, 

VA), March 2007. Qualifies for Navy CATEX (f) (39).

The proposed action was to relocate approximately 340 MDA personnel from a leased 

building in Crystal City, Arlington, VA to a facility located at the Naval Support Facility 

Dahlgren, Dahlgren, VA.

Reference: REC Realignment of Elements/Personnel of the MDA from NCR to Fort 

Belvoir, VA, March 2012. Qualifies for Army CATEX (b)14.

The proposed action was to move approximately 150 personnel from remaining off-base 

elements to a government facility in close proximity to MDA’s Headquarters facility on 

Ft. Belvoir, VA. This action is expected to be completed by FY 2015.

B-4. Routine procurement of goods and services conducted in accordance with applicable 

procurement regulations, Executive orders (EO), and policies to support operations and 

infrastructure, including routine utility services and contracts.

Procurement of goods and services and awarding of contracts for technical support services and 

other services included in this CATEX involve administrative activities. Activities contemplated 

by this CATEX are a variety of administrative activities performed in a similar nature, scope and 

intensity throughout the Agency and Federal government without significant environmental 

impacts. These activities are routine, day-to-day operations of MDA and the U.S. Government 

in general. None of the activities have the potential for significant environmental impacts when 

conducted in compliance with applicable Federal, state and local requirements.

The CATEX requires the procurement of goods and services to be conducted in accordance with 

Federal Acquisition Regulations, EOs, and Office of the Under Secretary of Defense, 

Acquisition, Technology and Logistics (OUSD (AT&L)) Directives, which will insure these

procurement activities meet policies and standards consistently applied across the U.S. 

Government, including the requirement to procure environmentally sustainable goods and 

services, when feasible. 

Recognizing these are routine, day-to-day activities required for the normal operation of the U.S. 

Government, the extensive history of the Services’ and other Federal agencies’ application of 

this CATEX and the lack of extraordinary circumstances associated with its application, this 

CATEX is determined to be applicable to MDA. As a DoD component, MDA conducts 

procurement activities in the same manner as the rest of the Services. MDA follows the same 

strict procurement and acquisition regulations, EO and DoD Directives as the Services. MDA’s 

procurement activities are dwarfed by the Military Services, which procure goods and services in 

much greater quantity and frequency than MDA. Furthermore, MDA has been using the existing 

Services’ CATEXs for the past 20 plus years.

13 October 2013
The Team noted numerous other Federal agencies have CATEXs for similar activities. MDA 

determined those activities were also similar in nature, scope and impact on the human 

environment to those performed by MDA. In addition, MDA recognized all Federal agencies, 

with very few exceptions, must meet the same requirements to protect the environment. The 

Team determined the characteristics of the activities at MDA were no different from those 

performed by other Federal agencies in general, as well as specifically related to the 

environment. 

Comparable Agency Categorical Exclusions and Administrative Records

U.S. Army 

Reference: 32CFR Part 651, Appendix B, Categorical Exclusions

(e)(1) Routine procurement of goods and services (complying with applicable procedures 

for sustainable or “green” procurement) to support operations and infrastructure, 

including routine utility services and contracts.

(e)(6) Acquisition or contracting for spares and spare parts, consistent with the approved 

Technical Data Package.

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(7) Routine procurement of goods and services conducted in accordance with applicable 

procurement regulations, executive orders, and policies. 

(12) Routine procurement, management, storage, handling, installation, and disposal of 

commercial items, where the items are used and handled in accordance with applicable 

regulations (e.g. consumables, electronic components, computer equipment, pumps).

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.1. Routine procurement of goods and services.

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(2) Routine procurement activities and actions for goods and services, including office 

supplies, equipment, mobile assets, and utility services for routine administration, 

operation, and maintenance.

14 October 2013
Federal Emergency Management Agency 

Reference: 44 CFR 10.8 (d) (2)

(vi) Procurement of goods and services for support of day-to-day and emergency 

operational activities, and the temporary storage of goods other than hazardous materials, 

so long as storage occurs on previously disturbed land or in existing facilities.

B-5. Administrative study efforts involving no commitment of resources other than 

personnel and funding allocations. If any of these study efforts result in proposals for 

further action, those proposals must be considered separately by an appropriate 

CATEX or NEPA analysis. Examples include, but are not limited to: studies 

conducted to further administrative, personnel-related, architectural, engineering, 

safety, security, siting, and facility audit activities.

The actions contemplated by this CATEX are a variety of administrative activities having no 

potential for significant environmental impacts. The Team found actions of a similar nature, 

scope and intensity were performed throughout the Agency and DoD without significant 

environmental impacts. MDA uses many of the same standard protocols and guidelines (i.e.,

DoD Directives, respective Service Instructions and Industry standards) for conducting these 

activities as the Services and they have had no significant environmental impacts. Insignificant 

impacts would include the minor resource use of paper, printer ink, and the small amount of 

energy required to produce study reports and transportation of personnel to and from study sites. 

An example of an action under this CATEX would be an environmental compliance audit, which 

requires a site visit, document review, and interviews with site personnel. No equipment is used 

and typically no sampling of environmental media occurs. MDA uses the same U.S. Corp of 

Engineers assessment protocols as most of the Military Services and Federal agencies. These

assessments are conducted annually for MDA facilities and have no observed environmental 

impacts. They are part of normal environmental, health and safety compliance type activities at

various locations around the country.

The Team determined the use of examples in this CATEX would be helpful to future users in 

clarifying the types of activities envisioned by the CATEX. In providing examples, MDA did 

not intend to limit the CATEX to those activities or to extend the CATEX to actions involving

extraordinary circumstances which might result in significant environmental effects. 

The Team recognized some of the activities contemplated by this CATEX could result in 

proposals for further action. To ensure these proposals would not promote activities with 

potential to significantly impact the quality of the human environment, the CATEX is 

specifically limited so if an activity results in a proposal, the new proposal’s environmental 

impacts would be evaluated either by another MDA CATEX or NEPA analysis. This limitation 

is in place to ensure there will be no potential for significant environmental impacts 

contemplated by the application of this CATEX. 

15 October 2013
As documented in Table B-5.1, the Team conducted a comparative analysis (or benchmarking) 

of MDA’s proposed CATEX to other applicable government organizations’ CATEXs. We 

compared the characteristics of the action, methods of implementing the action, frequency of the 

action, applicable regulations, applicable standard operating procedures (SOPs), timing and 

context, extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, must meet substantially the same 

requirements to protect the environment and employ SOPs to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent; and 

5) No known significant impacts are associated with this proposed activity. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA.

Comparable Agency Categorical Exclusions and Administrative Records

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(b)(8) Preparation of administrative or personnel-related studies, reports, or 

investigations.

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(4) Administrative studies, surveys and data collections.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.24. Study efforts that involve no commitment of resources other than personnel and 

funding allocations.

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(31) Planning and technical studies which do not contain recommendations for 

authorization or funding for future construction, but may recommend further study. This 

includes engineering efforts or environmental studies undertaken to define the elements 

16 October 2013
of a proposal or alternatives sufficiently so that the environmental effects may be 

assessed and does not exclude consideration of environmental matters in the studies.

Federal Emergency Management Agency 

Reference: 44 CFR 10.8 (d) (2)

(iii) Studies that involve no commitment of resources other than manpower and 

associated funding.

17 October 2013
Table B-5.1 Comparative Analysis of MDA CATEX B-5 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard Federal Emergency Management Agency

Notes

Applicable 

CATEXs B-5 (b)(8) (f)(4) A2.3.24 (31) 44 CFR 10.8 (d) (2)

(iii)

Characteristics of 

the Action

Administrative study efforts involving no 

commitment of resources other than 

personnel and funding allocations. 

These studies typically only require a site 

visit and/or a document review followed 

by an analysis and report preparation 

with conclusions or recommendations. 

For a site visit, surveys are typically of 

short duration not lasting more than a few 

days or a week at most. 

If any of these study efforts result in 

proposals for further action, those 

proposals must be subsequently analyzed. 

Examples include: Studies conducted in 

furtherance of administrative, personnelrelated, architectural, engineering, safety, 

security, siting and facility audit 

activities. 

Proposed action is limited to 

preparation of administrative or 

personnel-related studies, reports, or 

investigations.

MDA has extensive experience 

working at U.S. Army installations

such as the Ronald Reagan Test Site, 

U.S. Army Kwajalein Atoll (USAKA);

White Sands Missile Range (WSMR), 

NM; Redstone Arsenal, AL; Fort 

Greely, AK; Fort Drum, NY; and Fort

Belvoir, VA.

Proposed action is limited to 

administrative studies, surveys and data 

collections. 

MDA has extensive experience 

working at U.S. Navy installations such 

as Pacific Missile Range Facility, 

(PMRF), HI; Point Mugu Sea Range,

CA; San Nicolas Island, CA; and 

Dahlgren Naval Base, VA.

Proposed action is limited to study 

efforts that involve no commitment of 

resources other than personnel and 

funding allocations.

MDA has extensive experience 

working at U.S. Air Force Installations 

such as Vandenberg AFB, CA;

Edwards AFB, CA; Wake Island; Clear 

Air Force Station (AFS), AK;

Elmendorf AFB, AK; Eareckson AFS, 

AK; and Schriever AFB, CO.

Planning and technical studies which 

do not contain recommendations for 

authorization or funding for future 

construction, but may recommend 

further study. This includes 

engineering efforts or environmental 

studies undertaken to define the 

elements of a proposal or alternatives 

sufficiently so the environmental 

effects may be assessed and does not 

exclude consideration of environmental 

matters in the studies. 

Proposed action is limited to studies 

that involve no commitment of 

resources other than manpower and 

associated funding.

These are essentially desk top or site 

inspection studies only with no 

significant impacts on the physical 

environment.

Methods of 

Implementing the 

Action

Work with host installation or property 

owner to identify applicable laws, 

regulations, management plans, SOPs, 

and existing areas with known natural 

and/or cultural resources and/or 

environmental contamination.

Work with host installation or property 

owner to either review existing 

documentation and/or prepare necessary 

NEPA documentation.

Work with host installation to conduct 

any required coordination with Federal 

and state agencies.

Coordinate with installation staff to

identify applicable laws, regulations, 

management plans, SOPs, and existing 

areas with known natural and/or 

cultural resources and/or environmental 

contamination.

Coordinate with installation staff to 

either review existing documentation 

and/or prepare necessary NEPA 

documentation.

Conduct any required coordination 

with Federal and state agencies.

Same Same Coordinate with internal staff to

identify applicable laws, regulations, 

management plans, SOPs, and existing 

areas with known natural and/or 

cultural resources and/or environmental 

contamination.

Coordinate with internal staff to either 

review existing documentation and/or 

prepare necessary NEPA 

documentation.

Conduct any required coordination 

with Federal and state agencies.

Coordinate with internal staff and local 

public entity to identify applicable 

laws, regulations, management plans, 

SOPs, and existing areas with known 

natural and/or cultural resources and/or 

environmental contamination.

Coordinate with internal staff and local 

public entity to either review existing 

documentation and/or prepare 

necessary NEPA documentation.

Conduct any required coordination 

with Federal and state agencies.

Frequency of the 

Actions

These studies occur frequently. Same Same Same Same Same

Applicable 

Regulations

NEPA, Endangered Species Act (ESA), 

National Historic Preservation Act

(NHPA), Archaeological Resources 

Protection Act (ARPA), Comprehensive 

Environmental Response, Compensation 

and Liability Act (CERCLA), Clean 

Water Act (CWA), Clean Air Act (CAA), 

and other applicable Federal and state 

Regulations, DoD and Military Service 

requirements, and industry standards.

Same Same Same Same Same

Applicable SOPs Installation/Manufacturer specific Same Same Same Same Same

18 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard Federal Emergency Management Agency Notes

Timing and 

Context

Surveys could occur any time of the year. 

These are generally performed at a Host 

installation, although some studies could 

be performed at MDA-leased

administrative or warehouse facilities

located on commercial property.

Same Same Same Same Same

Extraordinary 

Circumstances

Follow-on intrusive investigations and 

actions could be required, but would be 

analyzed in a subsequent analysis.

Same Same Same Same Same.

Known Impacts 

from Proposed 

Action

After 20+ years of activity, MDA knows 

of no known significant impacts from 

these types of studies. 

Same Same Same Unknown (but expected to be similar) Unknown (but expected to be similar)

19 October 2013
B-6. Studies, monitoring, data and sample collection, and information gathering that 

involve no permanent physical change to the environment. If any of these activities 

result in proposals for further action, those proposals must be considered by an 

appropriate CATEX or NEPA analysis. Examples include, but are not limited to:

a. Surveys for threatened and endangered species, wildlife and wildlife habitat, 

historic properties and archeological sites; wetland delineations; minimal water, 

air, waste; material and soil sampling (e.g., grab samples);

b. Vulnerability, risk, and structural integrity assessments of infrastructure;

c. Environmental Baseline Surveys or Environmental Condition of Property 

Surveys; and

d. Topographical surveying and mapping that does not require cutting and/or 

removal of trees.

The Team determined the activities contemplated by this CATEX would have no potential for 

significant environmental impacts. Further, the Team found actions of a similar nature, scope 

and intensity were performed at MDA, the Services, and other Federal agencies by experienced 

subject matter experts (e.g., geologists, environmental scientists, biologists, archaeologists, 

environmental engineers, certified wetland scientist/delineators, security personnel, etc.)

following very strict protocols, SOPs, and processes to ensure no significant environmental 

impacts occur. In addition, MDA closely coordinates all studies with the host installation/range 

environmental specialists to further ensure a minimal impact to resources occurs.

These activities are not intrusive to the environment, as they involve the analysis and assessment 

of the natural environment without fundamentally altering it. These activities are typically of 

short duration, taking only a few days to complete, and generally, are not conducted at the same 

location again. The exception to this would include follow-on investigations, which would 

require additional analysis to ensure they would be covered by an appropriate CATEX or 

additional NEPA analysis. 

These activities are required by various Federal, state and DoD directives, laws and regulations 

and are thus part of normal day-to-day environmental compliance activities. For example, 

Military installations and all Federal facilities with federally designated endangered and 

threatened species must carry out programs for their conservation (50 C.F.R. 402.01(a), 402.10, 

402.12). Specific requirements include completing surveys to determine if the facility has any 

threatened or endangered species, preparation of installation management plans for natural 

resources and cultural resources, consultations with the U.S. Fish and Wildlife Service, National 

Marine Fisheries Service, and other agencies, and taking actions to comply with 

consultations/opinions received. By their nature these surveys tend to prevent and eliminate 

possible impacts, such as disturbance to threatened and endangered species and wildlife and its 

habitat, damage to historic properties and archeological sites, and alteration or loss of wetlands. 

In addition, these activities have been conducted by MDA for over 20 plus years in a wide range 

of environments ranging from tropical forests to ocean areas to desert to Arctic tundra without 

observing any significant adverse impacts.

The Team determined the use of examples would help clarify the types of activities envisioned 

by this CATEX. In providing examples, MDA did not intend to limit the CATEX to these 

20 October 2013
activities or to extend the CATEX to actions including extraordinary circumstances resulting in 

an activity having significant environmental effects.

The Team recognized some of the activities contemplated by this CATEX could result in 

proposals for further action. To ensure these proposals would not promote activities with the 

potential to significantly impact the quality of the human environment, if the study or activity 

results in a proposal, it must be supported by another MDA CATEX or NEPA analysis. This 

limitation is in place to ensure there will be no potential for significant environmental impacts 

contemplated by the application of this CATEX. 

As documented in Table B-6.1, the Team conducted a comparative analysis (or benchmarking) 

of MDA’s proposed CATEX to other applicable government organizations’ CATEXs. We 

compared the characteristics of the action, methods of implementing the action, frequency of the 

action, applicable regulations, applicable SOPs, timing and context, extraordinary circumstances, 

and known impacts from the proposed action. The Team determined that:

 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent; and 

5) No known significant impacts are associated with this proposed activity. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA.

Comparable Agency Categorical Exclusions and Administrative Records

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(d) (4) Studies, data collection, monitoring and information gathering that do not involve 

major surface disturbance. Examples include topographic surveys, bird counts, wetland 

mapping, and other resources inventories (REC required).

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(18) Studies, data, and information gathering that involve no permanent physical change 

to the environment (e.g., topographic surveys, wetlands mapping, surveys for evaluating 

environmental damage, and engineering efforts to support environmental analyses).

21 October 2013
U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.25. The analysis and assessment of the natural environment without altering it 

(inspections, audits, surveys, investigations). This CATEX includes the granting of any 

permits necessary for such surveys, provided that the technology or procedure involved is 

well understood and there are no adverse environmental impacts anticipated from it. The 

Environmental Planning Function (EPF) must document application of this CATEX on 

AF Form 813.

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(26) Data gathering, information gathering, and studies that involve no physical change 

to the environment. Examples include topographic surveys, bird counts, wetland 

mapping, and other inventories.

Federal Emergency Management Agency

Reference: 44 CFR § 10.8 (d) (2)

(iii) Studies that involve no commitment of resources other than manpower and 

associated funding.

(xviii) The following planning and administrative activities in support of emergency and 

disaster response and recovery: (D) Situation Assessment including ground and aerial 

reconnaissance; (E) Information and data gathering and reporting efforts in support of 

emergency and disaster response and recovery and hazard mitigation

Department of the Interior

Reference: Departmental Manual 516, Part 2, Appendix 1 Departmental Categorical 

Exclusions

1.6 Nondestructive data collection, inventory (including field, aerial, and satellite 

surveying and mapping), study, research, and monitoring activities.

Department of the Interior, U.S. Geological Survey 

Reference: Departmental Manual 516, Part 9. 9.5 Categorical Exclusions

A. Topographic, land use and land cover, geological, mineralogic, resources evaluation, 

and hydrologic mapping activities, including aerial topographic surveying, photography, 

and geophysical surveying. 

D. Well logging, aquifer response testing, digital modeling, inventory of existing wells 

and water supplies, water-sample collection. 

22 October 2013
E. Operation, construction and installation of: (a) Water-level or water quality recording 

devices in wells; (b) pumps in wells; (c) surface-water flow measuring equipment such as 

weirs and stream-gaging [sic] stations, and (d) telemetry systems, including contracts 

therefor [sic]. 

F. Routine exploratory or observation groundwater well drilling operations which do not 

require a special access road, and which use portable tanks to recycle and remove drilling 

mud, and create no significant surface disturbance. 

G. Test or exploration drilling and down-hole testing, including contracts therefore. 

H. Establishment of survey marks, placement and operation of field instruments, and 

installation of any research/monitoring devices. 

I. Digging of exploratory trenches requiring less than 20 cubic yards of excavation.

Department of the Interior, Bureau of Land Management 

Reference: Departmental Manual 516, Part 11. 11.5 Categorical Exclusions

F. Solid Minerals. 

(9) Digging of exploratory trenches for mineral materials, except in riparian areas. 

H. Other. 

(3) Conducting preliminary hazardous materials assessments and site investigations, site 

characterization studies and environmental monitoring. Included are siting, construction, 

installation and/or operation of small monitoring devices such as wells, particulate dust 

counters and automatic air or water samples. 

MDA Environmental Reviews

Reference: REC Geophysical Survey in Kuluk Bay at Adak, Alaska, March 2004. 

Qualifies for Army CATEX (d)4.

The proposed action was to perform a geophysical survey of Kuluk Bay at Adak, AK. 

The survey would include: 1) mapping the water depth and features on the seafloor; 2) 

mapping the thickness of unconsolidated sediment on the seafloor; 3) obtain sediment 

samples; and 4) make in-situ measurements of consolidation characteristic of sediment.

23 October 2013
Table B-6.1 Comparative Analysis of MDA CATEX B-6 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard

Notes

Applicable 

CATEXs B-6 (d)(4) (f)(18) A2.3.25 (26)

Characteristics 

of the Action

Studies, monitoring, data and sample 

collection, and information gathering that 

involve no permanent physical change to 

the environment. If any of these activities

result in proposals for further action, those 

proposals must be subsequently analyzed. 

These activities are not intrusive or only 

minimally so. Most activities consist of site 

inspections, existing document collection, 

and interviews with installation or 

regulatory agency personnel.

Activities are typically of short duration not 

lasting more than a few days or a week at 

most.

Proposed action is limited to studies, data 

collection, monitoring and information 

gathering that do not involve major surface 

disturbance. Examples include topographic 

surveys, bird counts, wetland mapping, and 

other resources inventories (REC required). 

MDA has extensive experience working at 

U.S. Army installations such as the Ronald 

Reagan Test Site, USAKA; WSMR, NM; 

Redstone Arsenal, AL; Fort Greely, AK; 

Fort Drum, NY; and Fort Belvoir, VA.

Proposed action is limited to studies, data, 

and information gathering that involve no 

permanent physical change to the 

environment (e.g., topographic surveys, 

wetlands mapping, surveys for evaluating 

environmental damage, and engineering 

efforts to support environmental analyses).

MDA has extensive experience working at 

U.S. Navy installations such as PMRF, HI; 

Point Mugu Sea Range, CA; San Nicolas 

Island, CA; and Dahlgren Naval Base, VA.

Proposed action is limited to the analysis 

and assessment of the natural environment 

without altering it (inspections, audits, 

surveys, investigations). This CATEX 

includes the granting of any permits 

necessary for such surveys, provided the 

technology or procedure involved is well 

understood and there are no adverse 

environmental impacts anticipated from it. 

The EPF must document application of this 

CATEX on AF Form 813.

MDA has extensive experience working at 

U.S. Air Force Installations such as 

Vandenberg AFB, CA; Edwards AFB, CA; 

Wake Island; Clear AFS, AK; Elmendorf 

AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

Proposed action is limited to data gathering, 

information gathering, and studies that 

involve no physical change to the 

environment. Examples include 

topographic surveys, bird counts, wetland 

mapping, and other inventories.

Limited time, intensity and frequency 

reduce the potential effects of the proposed 

action.

Methods of 

Implementing 

the Action

Work with host installation or property 

owner to identify applicable laws, 

regulations, management plans, SOPs, and 

existing areas with known natural and/or 

cultural resources and/or environmental 

contamination.

Work with host installation or property 

owner to either review existing 

documentation and/or prepare necessary 

NEPA documentation.

Work with host installation to conduct any 

required coordination with Federal and state 

agencies.

Activities would be conducted by qualified 

professionals (geologists, environmental 

scientists, biologists, archaeologists, 

environmental engineers, certified wetland 

scientist/delineators, surveyors and security 

personnel).

Coordinate with installation staff to identify 

applicable laws, regulations, management 

plans, SOPs, and existing areas with known 

natural and/or cultural resources and/or 

environmental contamination.

Coordinate with installation staff to either 

review existing documentation and/or 

prepare necessary NEPA documentation.

Conduct any required coordination with 

Federal and state agencies.

Activities would be conducted by qualified 

professionals (geologists, environmental

scientists, biologists, archaeologists, 

environmental engineers, certified wetland 

scientist/delineators, surveyors and security 

personnel).

Same Same Coordinate with internal staff to identify 

applicable laws, regulations, management 

plans, SOPs, and existing areas with known 

natural and/or cultural resources and/or 

environmental contamination.

Coordinate with internal staff to either 

review existing documentation and/or 

prepare necessary NEPA documentation.

Conduct any required coordination with 

Federal and state agencies.

Activities would be conducted by qualified 

professionals (geologists, environmental 

scientists, biologists, archaeologists, 

environmental engineers, certified wetland 

scientist/delineators, surveyors and security 

personnel).

All these activities are conducted according 

to defined protocols that are fundamentally 

consistent across Federal agencies and by 

certified or otherwise qualified 

professionals.

Frequency of the 

Actions

Generally one time in one area. However, 

in the case of cultural or threatened and 

endangered species surveys, multiple 

surveys may be necessary.

Same Same Same Same Range operations are subject to conditions 

of installation’s regulatory permits, cultural 

resource and natural resource management 

plans, and environmental restoration 

program.

Applicable 

Regulations

NEPA, ESA, NHPA, ARPA, CERCLA, 

CWA, CAA, and other applicable Federal 

and state regulations, DoD and Military 

Services requirements, and industry 

standards.

Same Same Same Same

24 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard Notes

Applicable SOPs Installation/Manufacturer specific Same Same Same Same

Timing and 

Context

Surveys could occur any time of the year. 

Some biological surveys may be only 

conducted during growing season or when 

species are present, if migratory.

Same Same Same Same

Extraordinary 

Circumstances

If follow-on intrusive investigations and 

actions are required, they would be covered 

by another appropriate CATEX or NEPA 

analysis.

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows 

of no known significant impacts from these 

types of surveys. 

Same Same Same Unknown (but expected to be similar)

25 October 2013
B-7. Sampling, well drilling and installation, analytical testing, site preparation and 

minimally intrusive physical testing. These activities could involve minor clearing and

grubbing or movement of heavy equipment such as drill rigs. If any of these actions 

result in proposals for further actions, those proposals must be considered by an 

appropriate CATEX or NEPA analysis. Examples include, but are not limited to:

a. Sampling for asbestos containing materials (ACM), polychlorinated biphenyls 

(PCB), lead-based paint (LBP);

b. Topographical surveys and surveys for unexploded ordnance; 

c. Minimally-intrusive geological, geophysical surveys, and geo-technical activities, 

seismic studies;

d. Minimally-intrusive sampling to determine if hazardous wastes, contaminants, 

pollutants, or special hazards are present; or 

e. Ground-water monitoring wells, subsurface soil sampling and soil borings.

(REC required.)

MDA determined the activities contemplated by this CATEX have no potential for significant 

environmental impacts. As long as there were no extraordinary circumstances (e.g., presence of 

endangered or threatened species, presence of cultural resources, etc.), activities commonly 

undertaken when conducting a site survey prior to selecting a parcel for constructing a facility 

(e.g., surveying, determining depth to ground water, identifying soil characteristics, establishing 

baseline site conditions, etc.) do not have the potential to significantly impact the environment 

because they do not affect or change the environment. 

To ensure extraordinary circumstances are not present and that only those actions having 

negligible impacts on the human environment are contemplated, the Team proposed a REC be 

prepared to document no extraordinary circumstances exist and all CATEX use criteria are met, 

or whether the action requires further analysis through the NEPA process.

The Team determined the use of examples would help clarify the types of activities envisioned 

by this CATEX and those of CATEX B-6. In providing examples, MDA did not intend to limit 

the CATEX to those activities or to extend the CATEX to actions including extraordinary 

circumstances resulting in the activity having significant environmental effects.

MDA recognized some of the activities contemplated by this CATEX could result in proposals 

for further action. To ensure these proposals would not promote activities with potential to 

significantly impact the quality of the human environment, if the activities described in this 

CATEX results in a proposal, the proposal must be supported by another MDA CATEX or 

NEPA analysis. This limitation is in place to ensure there will be no potential for significant 

environmental impacts contemplated by the application of this CATEX.

As predicted by MDA in an EA prepared to assess the potential impacts posed by MDA’s 

proposal to conduct a geotechnical investigation and a topographic survey of a 60-acre site, no 

significant environmental impacts were identified or observed during the EA analysis or by 

USAF environmental management professionals following completion of the project. 

26 October 2013
Further, based upon the extensive history of the Services’ and other Federal agencies’ application 

of this CATEX and the lack of extraordinary circumstances associated with its application, the 

Team determined that this CATEX to conduct sampling, surveying, well drilling and installation, 

analytical testing, site preparation, and intrusive testing to determine if hazardous wastes, 

contaminants, pollutants, or special hazards are present is similarly used by the Military Services

and other Federal agencies. 

The same industry standards, protocols and guidelines are used by MDA and the Services. 

These activities are conducted because they are required by Federal and state regulations or 

Service directives and because they are necessary to protect human health and the environment. 

These activities are conducted by only qualified or certified professionals and are conducted in 

essentially the same manner throughout the Federal Government. Federal and state requirements 

dictate the manner in which they must be performed. Furthermore, possible negative impacts 

have been recognized by the regulators and procedures have been developed to prevent negative 

impacts. For example, to prevent contamination or cross-contamination of groundwater aquifers, 

there are requirements that all equipment that may encounter contaminated formation materials 

must be decontaminated prior to drilling each new borehole, and sampling equipment must be 

decontaminated between sampling intervals. Decontamination fluids must be captured, 

containerized, and properly disposed according to recommended procedures and regulations. 

The Services, which are hosts at locations where MDA conducts the majority of its activities, 

conduct similar activities to those conducted by MDA on a much larger scale than MDA, and

have CATEXs encompassing the types of activities contemplated for this MDA CATEX. In 

addition, MDA recognized all Federal agencies, with very few exceptions, must meet the same 

requirements to protect the environment.

As documented in Table B-7.1, the Team conducted a comparative analysis (or benchmarking) 

of MDA’s proposed CATEX to other applicable government organizations’ CATEXs. We 

compared the characteristics of the action, methods of implementing the action, frequency of the 

action, applicable regulations, applicable SOPs, timing and context, extraordinary circumstances, 

and known impacts from the proposed action. The Team determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent and documented by a

REC; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

27 October 2013
Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusions and Administrative Records

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(h) (3) Sampling, surveying, well drilling and installation, analytical testing, site 

preparation, and intrusive testing to determine if hazardous wastes, contaminants, 

pollutants, or special hazards (for example, asbestos, PCBs, lead-based paint, or 

unexploded ordnance) are present (REC required).

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.26. Undertaking specific investigatory activities to support remedial action activities 

for purposes of cleanup of Environmental Restoration Account - Air Force and RCRA 

corrective action sites. These activities include soil borings and sampling, installation, 

and operation of test or monitoring wells. This CATEX applies to studies that assist in 

determining final cleanup actions when they are conducted in accordance with legal 

agreements, administrative orders, or work plans previously agreed to by Environmental 

Protection Agency (EPA) or state regulators.

Department of the Interior, U.S. Geological Survey 

Reference: Departmental Manual 516, Part 9, 9.5 Categorical Exclusions.

A. Topographic, land use and land cover, geological, mineralogic, resources evaluation, 

and hydrologic mapping activities, including aerial topographic surveying, photography, 

and geophysical surveying. 

D. Well logging, aquifer response testing, digital modeling, inventory of existing wells 

and water supplies, water-sample collection. 

E. Operation, construction and installation of: (a) Water-level or water quality recording 

devices in wells; (b) pumps in wells; (c) surface-water flow measuring equipment such as 

weirs and stream-gauging stations, and (d) telemetry systems, including contracts 

therefore. 

F. Routine exploratory or observation groundwater well drilling operations which do not 

require a special access road, and which use portable tanks to recycle and remove drilling 

mud, and create no significant surface disturbance. 

G. Test or exploration drilling and down-hole testing, including contracts therefore. 

28 October 2013
H. Establishment of survey marks, placement and operation of field instruments, and 

installation of any research/monitoring devices. 

I. Digging of exploratory trenches requiring less than 20 cubic yards of excavation.

Department of the Interior, Bureau of Land Management

Reference: Departmental Manual 516, Part 11. 11.5 Categorical Exclusions

F. Solid Minerals. (9) Digging of exploratory trenches for mineral materials, except in 

riparian areas. 

H. Other. (3) Conducting preliminary hazardous materials assessments and site 

investigations, site characterization studies and environmental monitoring. Included are 

siting, construction, installation and/or operation of small monitoring devices such as 

wells, particulate dust counters and automatic air or water samples.

Department of the Interior, Bureau of Reclamation 

Reference: Departmental Manual 516, Part 14. 14.5 Categorical Exclusions

(3) Data collection studies that involve test excavations for cultural resources 

investigations or test pitting, drilling, or seismic investigations for geologic exploration 

purposes where the impacts will be localized.

Missile Defense Agency Environmental Reviews

Reference: National Missile Defense Geotechnical Investigation and Topographic 

Survey at Clear Air Station, Alaska Environmental Assessment, December 1999, 

resulting in FONSI

Note: Only one MDA NEPA document was found that incorporates discussion of the 

type of activities included in the proposed MDA CATEX. This is because such activities 

are conducted routinely with minimal environmental impacts and are rarely analyzed in 

an EA and resulting FONSI. 

The Proposed Action was to conduct a topographic survey to determine the elevations of 

the land and a geotechnical investigation to determine soil and rock conditions at the site. 

Activities included all clearing necessary to do the topographic survey and geotechnical 

work and any new access roads necessary to conduct geotechnical borings.

Design of the Ground-based Interceptor (GBI) facilities requires ground topographic 

mapping with 1-foot contour intervals. To achieve this resolution, survey lines would be 

cleared for a required hand survey with laser equipment and control markers. These lines 

would be hand cut by machete and chainsaw just wide enough to allow for the survey to 

proceed, typically 2 to 3 feet. Approximately 60 5,000-foot survey lines would be 

required.

29 October 2013
Some clearing of brush and vegetation would be required before the actual geotechnical 

investigation to enable access, staging of drilling supplies, equipment set-up, and 

operation. Clearing of trails for the geotechnical equipment would affect approximately 

60 acres. There would be approximately 150 borings.

A total of 10 percolation tests would be conducted in accordance with EPA approved 

procedures. Ground penetrating radar (GPR) survey would be conducted along the 

proposed alignment of the GBI silos in areas cleared as part of the access trails to assist in 

interpreting the depth and extent of the permafrost.

Analysis of potential environmental impacts of the Proposed Action concluded that no 

significant impacts to Clear AFS would occur. No significant environmental impacts 

were reported or observed during these activities at Clear AFS or after their completion.

30 October 2013
Table B-7.1 Comparative Analysis of MDA CATEX B-7 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Air Force U.S. Dept. of the Interior, U.S. Geological Survey

U.S. Department of the Interior, 

Bureau of Land Management

Notes

Applicable 

CATEXs B-7 (h)(3) A2.3.26 Departmental Manual 516, Part 9, 9.5 Departmental Manual 516, Part 11. 11.5

Characteristics 

of the Action

Sampling, well drilling and installation, 

analytical testing, site preparation, and 

minimally intrusive physical testing. These 

activities could involve minor clearing and 

grubbing, or movement of heavy equipment 

such as drill rigs and do not permanently 

change the environment.

Installation and operation of equipment is 

confined to host installation (or in 

extremely limited instances, private 

property where similar actions are 

permitted).

Activities are typically of short duration not 

lasting more than a few days or a week at 

most and rarely repeated at the same 

location.

(h) (3) Proposed action is limited to 

sampling, surveying, well drilling and 

installation, analytical testing, site 

preparation, and intrusive testing to 

determine if hazardous wastes, 

contaminants, pollutants, or special hazards 

(for example, asbestos, PCBs, lead-based 

paint, or unexploded ordnance) are present 

(REC required)

MDA has extensive experience working at 

U.S. Army installations such as the Ronald 

Reagan Test Site, USAKA; WSMR, NM; 

Redstone Arsenal, AL; Fort Greely, AK; 

Fort Drum, NY; and Fort Belvoir, VA.

Proposed action is limited to undertaking 

specific investigatory activities to support 

remedial action activities for purposes of 

cleanup of Environmental Restoration 

Account (ERA) - Air Force and RCRA 

corrective action sites. These activities 

include soil borings and sampling, 

installation, and operation of test or 

monitoring wells. This CATEX applies to 

studies that assist in determining final 

cleanup actions when they are conducted in 

accordance with legal agreements, 

administrative orders, or work plans 

previously agreed to by EPA or state 

regulators.

MDA has extensive experience working at 

U.S. Air Force Installations such as 

Vandenberg AFB, CA; Edwards AFB, CA; 

Wake Island; Clear AFS, AK; Elmendorf 

AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

A. Topographic, land use and land cover, 

geological, mineralogic, resources 

evaluation, and hydrologic mapping 

activities, including aerial topographic 

surveying, photography, and geophysical 

surveying. 

D. Well logging, aquifer response testing, 

digital modeling, inventory of existing wells 

and water supplies, water-sample collection.

 

E. Operation, construction and installation 

of: (a) Water-level or water quality 

recording devices in wells; (b) pumps in 

wells; (c) surface-water flow measuring 

equipment such as weirs and streamgauging stations, and (d) telemetry systems, 

including contracts therefore. 

F. Routine exploratory or observation 

groundwater well drilling operations which 

do not require a special access road, and 

which use portable tanks to recycle and 

remove drilling mud, and create no 

significant surface disturbance. 

G. Test or exploration drilling and 

downhole testing, including contracts 

therefore. 

H Establishment of survey marks, 

placement and operation of field 

instruments, and installation of any 

research/monitoring devices. 

I. Digging of exploratory trenches requiring 

less than 20 cubic yards of excavation

F. Solid Minerals. (9) Digging of 

exploratory trenches for mineral materials, 

except in riparian areas. 

H. Other. (3) Conducting preliminary 

hazardous materials assessments and site 

investigations, site characterization studies 

and environmental monitoring. Included are 

siting, construction, installation and/or 

operation of small monitoring devices such 

as wells, particulate dust counters and 

automatic air or water samples. 

Temporary nature of activity limits the 

potential effects of the proposed action.

Limited clearing and grubbing, and 

movement of heavy equipment minimizes

potential impacts from activities.

Applying operating conditions per federal, 

state and installation requirements 

minimizes potential impacts.

Methods of 

Implementing 

the Action

Work with host installation or property 

owner to identify applicable laws, 

regulations, management plans, SOPs, and 

existing areas with known natural and/or 

cultural resources and/or environmental 

contamination.

Work with host installation or property 

owner to either review existing 

documentation and/or prepare necessary 

NEPA documentation.

Work with host installation to conduct any 

required coordination with Federal and state 

agencies.

Coordinate with installation staff to identify 

applicable laws, regulations, management 

plans, SOPs, and existing areas with known 

natural and/or cultural resources and/or 

environmental contamination.

Coordinate with installation staff to either 

review existing documentation and/or 

prepare necessary NEPA documentation.

Conduct any required coordination with 

Federal and state agencies.

Remove equipment, drilling wastes, 

investigation of derived wastes, close wells, 

and restore site to original condition (or 

Same Similar Similar

31 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Air Force U.S. Dept. of the Interior, U.S. Geological Survey

U.S. Department of the Interior, 

Bureau of Land Management Notes

Remove equipment, drilling wastes, 

investigation of derived wastes, close wells,

and restore site to original condition (or 

agreed upon condition – e.g., leaving behind 

gravel roads, storm water controls, or 

survey monuments.)

agreed upon condition – e.g., leaving behind 

gravel roads, storm water controls, or 

survey monuments.)

Frequency of the 

Actions

Generally one time. Same Same Same Same

Applicable 

Regulations

NEPA, ESA, RCRA, CERCLA, CWA, 

CAA, and other applicable Federal and state 

regulations, DoD and Military Service 

requirements, and industry standards.

Same plus USAKA Environmental 

Standards (UES)

Same Same Same

Applicable SOPs U.S. EPA Test Methods and installation 

plans and operating procedures.

Same Same Same Same

Timing and 

Context

Activities could occur any time of the year. 

These activities occur within the context of 

installation environmental management 

programs.

Same Same Same Same

Extraordinary 

Circumstances

Presence of endangered or threatened 

species, cultural/historic resources, 

contaminated media or aquifers, or 

hazardous materials/wastes.

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows 

of no known significant impacts from these 

activities. Potential impacts are mitigated 

using established protocols and procedures. 

Contaminated media is removed and treated 

in accordance with (IAW) applicable 

regulations.

Same Same Unknown (but expected to be similar) Unknown (but expected to be similar)

32 October 2013
B-8. Immediate responses to the release or discharge of oil or hazardous materials in 

accordance with an approved Spill Prevention, Control and Countermeasure (SPCC) 

Plan or Spill Contingency Plan, or that is otherwise consistent with the requirements of 

the EPA National Contingency Plan.

This CATEX is specifically limited to MDA actions conducted in a manner consistent with 

previously established and approved SPCC Plan or Spill Contingency Plan procedures and in 

compliance with Federal, state, and local requirements to protect the environment, and actions 

conducted in a manner that will result in no, or de minimis, change in the use of the facility or 

site. These plans are required by Federal and state regulations to address the prevention of 

accidental discharges of oil and hazardous substances and to control them when they do occur so 

as to minimize their impact on the environment. These plans describe and stipulate actions that 

must be taken to prevent spills or releases of oil or hazardous materials from occurring (i.e.,

types of storage containers, type and size of secondary containment, spill and over fill prevention 

controls, maintenance/inspection schedules, etc.). These plans further outline immediate actions 

to be taken in response to a release or discharge of hazardous materials. The intent of this 

CATEX is to include those actions that must be taken immediately to minimize the impacts of a 

spill to the environment. Minor releases do not pose a danger to personnel, property, and/or the 

environment and can be safely and competently controlled, contained, and cleaned up by site 

personnel. Immediate responses could include, but are not limited to, stopping the product flow 

and shutting off all ignition sources, followed by containment, control, and mitigation of the 

discharge. Mitigation could involve contaminated media being removed and treated IAW

applicable regulations

An example of the type of activities that might require an immediate response to a release or spill 

would be when MDA operates emergency back-up generators for many of their mission critical 

assets. These generators run on either natural gas or diesel fuel, which is stored in steel-lined 

tanks (or rubber fuel bladders at deployed sites) with secondary containment. In the unlikely 

event a spill or discharge occurred from any of these diesel fuel tanks, the diesel fuel would be 

contained within the secondary containment structure and impacts to the environment would be 

minor or non-existent. However, if the spill were not contained within the secondary 

containment, MDA would follow the host installation/range’s SPCC Plan for immediate 

response and containment, and would coordinate with appropriate emergency response personnel 

to ensure no significant impacts to the environment or human health would occur during cleanup. For those rare occasions that MDA would site these types of assets on commercial or 

industrial property, MDA would ensure a SPCC Plan has been developed in accordance with 

EPA guidelines.

As documented in Table B-8.1, the Team conducted a comparative analysis (or benchmarking) 

of MDA’s proposed CATEX to other applicable government organizations’ CATEXs. We 

compared the characteristics of the action, methods of implementing the action, frequency of the 

action, applicable regulations, applicable SOPs, timing and context, extraordinary circumstances, 

and known impacts from the proposed action. The Team determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

33 October 2013
2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent; and 

5) No known significant impacts are associated with this proposed activity. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusions and Administrative Records

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(h)(2) Immediate responses in accordance with emergency response plans (for example, 

Spill Prevention Control and Countermeasure Plan (SPCCP)/Installation Spill 

Contingency Plan (ISCP), and Chemical Accident and Incident Response Plan) for 

release or discharge of oil or hazardous materials/substances; or emergency actions taken 

by Explosive Ordnance Demolition (EOD) detachment or Technical Escort Unit.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.30. Immediate responses to the release or discharge of oil or hazardous materials in 

accordance with an approved Spill Prevention and Response Plan or Spill Contingency 

Plan or that are otherwise consistent with the requirements of the National Contingency 

Plan.

Defense Logistics Agency

Reference: Defense Logistics Agency Technical Support Document, Categorical 

Exclusions Evaluations

(24) Immediate responses to the release or discharge of oil or hazardous materials in 

accordance with an approved Spill Prevention and Response Plan or Spill Contingency 

Plan or that are otherwise consistent with the requirements of the National Contingency 

Plan. (Defense Logistics Agency (DLA) Form 1664 required).

34 October 2013
Table B-8.1 Comparative Analysis of MDA CATEX B-8 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Air Force Defense Logistics Agency

Notes

Applicable 

CATEXs B-8 (h)(2) A2.3.30 Defense Logistics Agency Technical Support 

Document, Categorical Exclusions Evaluations

Characteristics 

of the Action

Immediate responses to the release or discharge of small 

amounts of oil or hazardous materials in accordance with an 

approved Spill Prevention and Response Plan or Spill 

Contingency Plan, or that are otherwise consistent with the 

requirements of the National Contingency Plan.

Emergency generators powered by diesel fuel are generally 

installed and operated on host installations or leased property 

and all have secondary containment. Spills and releases are 

infrequent and generally occur during material transfer 

operations. 

Response actions are only conducted during emergency 

situations so as to prevent harm to the environment. The 

response may include such actions as application of absorbent 

materials, fire- fighting foams, temporary boom or dikes, or 

pumping and collection of liquids. In serious cases, 

evacuations of nearby personnel or offices could be required.

Proposed action is limited to immediate responses 

in accordance with emergency response plans (for 

example, SPCC Plan/Installation Spill 

Contingency Plan, and Chemical Accident and 

Incident Response Plan for release or discharge of 

oil or hazardous materials/substances; or 

emergency actions taken by EOD detachment or 

Technical Escort Unit.

MDA has extensive experience working at U.S. 

Army installations such as the Ronald Reagan 

Test Site, USAKA; WSMR, NM; Redstone 

Arsenal, AL; Fort Greely, AK; Fort Drum, NY; 

and Fort Belvoir, VA.

Proposed action is limited to the immediate 

responses to the release or discharge of oil or 

hazardous materials in accordance with an 

approved Spill Prevention and Response Plan or

Spill Contingency Plan or that are otherwise 

consistent with the requirements of the National 

Contingency Plan.

MDA has extensive experience working at U.S. 

Air Force Installations such as Vandenberg AFB, 

CA; Edwards AFB, CA; Wake Island; Clear AFS, 

AK; Elmendorf AFB, AK; Eareckson AFS, AK; 

and Schriever AFB, CO.

Immediate responses to the release or discharge of 

oil or hazardous materials in accordance with an 

approved Spill Prevention and Response Plan or 

Spill Contingency Plan or that are otherwise 

consistent with the requirements of the National 

Contingency Plan. (DLA Form 1664 required) 

Immediate actions are required to prevent adverse, 

and in some cases potentially catastrophic 

impacts.

Detailed response procedures contained in spill 

response plans minimize potential impacts from 

response actions.

Impacts of these types of responses are welldocumented, and are almost always positive in the 

sense of preventing or minimizing an uncontrolled 

release of oil or a hazardous substance to the 

environment.

There is 30+ years of experience with these 

procedures throughout Federal agencies and the 

private sector.

Methods of 

Implementing 

the Action

Work with host installation or property owner to prevent and 

control accidental discharges/releases and to ensure MDA 

activities are included in appropriate SPCC Plans.

Work with host installation or property owner to identify 

applicable laws, regulations, and SOPs.

Work with host installation or property owner to make sure 

required spill containment and response equipment is in place 

and functioning properly.

Work with host installation or property owner to report 

incidents to appropriate regulatory authorities.

Remove response equipment and dispose of all waste 

materials in compliance with Federal, state, DoD, and Service 

requirements.

Installation staffs to ensure all operations prevent

and control accidental discharges/releases and 

ensure all activities are included in installation 

SPCC Plans.

Installation staff identifies applicable laws, 

regulations, and SOPs.

Installation staffs make sure required spill 

containment and response equipment are in place 

and functioning properly for Army operations and 

ensure tenants do the same. 

Remove response equipment and dispose of all 

waste materials in compliance with Federal, state, 

DoD, and Service requirements.

Same Similar Implementation of emergency response 

procedures at a host installation, test ranges and 

private property is an infrequent, but well planned 

and documented activity, which conforms to the 

appropriate spill response plans.

Frequency of the 

Actions Infrequent (in almost all cases). Same Same Similar

Applicable 

Regulations

NEPA, RCRA, CERCLA, CWA, Federal and state regulations 

and guidance documents

Same, plus UES Same Similar

Applicable SOPs Detailed procedures incorporated in the plans themselves. Same Same Similar

Timing and 

Context

Activities could occur any time of the year without warning. 

These activities usually occur within the context of installation 

environmental management programs or spill response plans.

Same Same Similar

Extraordinary 

Circumstances

A large release or one that either occurred in a sensitive 

environment during transport or reached a sensitive 

environment could require additional documentation if longer 

term responses are required.

Same Same Similar

35 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Air Force Defense Logistics Agency Notes

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known 

significant impacts from these activities. Potential impacts are 

avoided or minimized using established protocols and 

procedures. Contaminated media is removed and treated IAW 

applicable regulations.

Same Same Unknown (but expected to be similar)

36 October 2013
B-9. Temporary use of transportable power generators or operational support 

equipment when located in a previously disturbed area and when operated in 

compliance with applicable regulatory requirements.

The temporary use of transportable power generators or operational support equipment 

contemplated by this CATEX is limited to those operated in compliance with applicable 

regulatory requirements and would be located in previously disturbed areas and operated to 

minimize disruption to the on-going activities at the existing site.

Specifically, limiting the CATEX to only those generators that are operated in compliance with 

applicable regulatory requirements ensures that: 

1) Generator emissions meet permitted levels, which minimizes potential impacts to air 

resources, biological resources, and human health; 

2) Generators are operated for specified allowed time periods, which minimize both total and 

cumulative emissions (air and noise); 

3) Generator fuel storage and refilling activities are conducted in a protective manner and spill 

prevention procedures and cleanup procedures are identified and followed; 

4) Site lighting is designed to minimize light “shine” and potential impact to animals at night;

and 

5) Generator operators are properly trained. 

In addition, limiting the CATEX to only those generators and equipment that are sited in 

previously disturbed areas minimizes the potential impact to sensitive environments, biological 

resources, and cultural resources. Furthermore, limiting the CATEX to only those generators 

and operational support equipment that will be short term in duration minimizes the potential 

impacts from their use (if any). 

The Team realized that minor trenching for running power cables could be required for safety 

reasons, if the cables could not rest on the surface of the ground or existing conduit were 

unavailable, but believed, based on our experience at host installations and test ranges, trenching 

(<3 feet deep) would be limited to existing easements and previously disturbed areas. By 

confining trenching to previously disturbed areas, existing easements, and shallow depths, we are 

minimizing the potential impact to sensitive environments, biological and cultural resources (i.e., 

less likely to run into a biological or cultural resource if the area was either in an existing 

easement or already disturbed and the depth of the trenching was limited to <3 feet).

As documented in Table B-9.1, the Team conducted a comparative analysis (or benchmarking) 

of MDA’s proposed CATEX to other applicable government organizations’ CATEXs. We 

compared the characteristics of the action, methods of implementing the action, frequency of the 

action, applicable regulations, applicable standard operating procedures (SOPs), timing and 

context, extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

37 October 2013
2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application is absent; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record 

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(e)(2) Acquisition, installation, and operation of utility and communication systems, 

mobile antennas, data processing cable and similar electronic equipment that use existing 

right-of-way, easement, distribution systems, and/or facilities (REC required).

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(f)(15) Modification of existing systems or equipment when the environmental effects 

will remain substantially the same and the use is consistent with applicable regulations.

(f) (36) Acquisition, installation, and operation of utility (e.g., water, sewer, electrical) 

and communication systems (e.g., data processing cable and similar electronic 

equipment) which use existing rights of way, easements, distribution systems, and/or 

facilities.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.12. Installing, operating, modifying, and routinely repairing and replacing utility 

and communications systems, data processing cable, and similar electronic equipment 

that use existing rights of way, easements, distribution systems, or facilities.

38 October 2013
U.S. Department of Rural Utilities Services

Reference: 7 CFR, 1794.3, Rural Utilities Services Environmental Policies and 

Procedures

Construction of standby diesel electric generators (one megawatt or less total capacity) 

and associated facilities, for the primary purpose of providing emergency power, at an 

existing applicant headquarters or district office, telecommunications switching site, or at 

an industrial, commercial or agricultural facility served by the applicant.

Missile Defense Agency Environmental Reviews

Reference: Theater High Altitude Area Defense (THAAD) Pacific Test Flights 

Environmental Assessment, December 2002, resulting in a FONSI

Numerous proposed activities were analyzed, including the operation of THAAD prime 

power units, each of which provided >1.3 megawatts of power using multiple dieselfueled generators. Thirteen broad areas of environmental consideration were considered 

for assessing potential impacts and MDA determined that no significant impacts would 

occur as a result of the construction and operation of the THAAD generators and other 

equipment. 

Over the course of 6 years, MDA conducted a-half dozen THAAD tests at PMRF and no 

environmental impacts were observed, as documented in mitigation monitoring reports.

Reference: Ground-Based Midcourse Defense (GMD) Extended Test Range (ETR) 

Environmental Impact Statement, July 2003

Numerous proposed activities were analyzed, including the use of diesel-fueled power 

generators to support transportable radars, communications equipment, and various 

supporting equipment. Fourteen broad areas of environmental consideration were 

considered for assessing potential impacts and MDA determined that the use of these 

generators and support equipment would not have significant environmental effects.

Since the construction of the GMD ETR, MDA has conducted an average of one to two 

flight tests per year with no observed environmental impacts from siting or operating 

transportable power generators or support equipment.

Reference: Missile Defense Agency Ground-Based Midcourse Defense Northeast 

Remote In-Flight Interceptor Communication System Data Terminal Environmental 

Assessment, May 2004, resulting in a FONSI

Numerous proposed activities were analyzed, including the installation and operation of 

emergency diesel generators and support equipment on a permanent basis. Between 

generator testing and operations during power outages, it is estimated that the onsite 

backup generators would operate for less than 500 hours per year, every year for the life 

of the Integrated Data Terminal (IDT) Support Facility (ISFAC). Thirteen broad areas of 

environmental consideration were considered for assessing potential impacts and MDA 

39 October 2013
determined that the use of these generators and support equipment would not have 

significant environmental effects. 

Construction of the IDT is planned to begin in FY 2015. A review of the proposed 

activities under the current EA determined no further NEPA analysis was needed.

Reference: Missile Defense Agency Mobile Launch Platform (MLP) Environmental

Assessment, June 2004, resulting in a FONSI

Numerous proposed activities were analyzed, including the use of diesel-fueled 

generators to power BMDS test equipment and sensors. Thirteen broad areas of 

environmental consideration were considered for assessing potential impacts and MDA 

determined that no significant impacts would occur as a result of generator use and 

support equipment operations. 

The MLP has been used on two to five missions per year since 2005 and no 

environmental impacts have been observed.

Reference: Mobile Sensors Environmental Assessment, September 2005, resulting in 

a FONSI 

Numerous proposed activities were analyzed; including a wide range in size of dieselfueled generators to power BMDS test sensors and supporting equipment. For example:

• MPS-36 radar would be powered by a 500 kilowatt generator

• Mk-74 would be powered by a 250 kilowatt generator

• Radar Boresight Tower system would require a 5 kilowatt generator

• Mobile Range Safety System would be powered by two 100 kilowatt generators 

and a 50 kilowatt generator powering the communication shelter

• Stabilized High-Accuracy Optical Tracking System would be powered by a 50 

kilowatt generator

• Rapid Optical Beam Steering Mobile Optical Tracking System would be powered 

by an 80 kilowatt generator.

Thirteen broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that the use of these generators and support 

equipment would not have significant environmental effects. Specifically, the EA stated 

that emissions associated with the generators would impact local air quality; however, 

even if the emissions occurred within the most stringent nonattainment area associated 

with the land-based test sites (a severe nonattainment area for ozone); the emission values 

would most likely not exceed the de minimis emission levels. In addition, because the 

location where the mobile land-based sensors and their associated generators and 

equipment would be used are generally within active test ranges, sensitive populations 

(children, elderly) or locations (schools, population centers) would not be located near 

such emission sources. Lastly, MDA would be required to notify regulators, obtain all 

necessary permits, and in some cases complete an Air Conformity Applicability Analysis.

40 October 2013
MDA has conducted numerous test activities using mobile sensors and their supporting 

diesel-fueled generators and support equipment, including the operation of the AN/TPY2 radar in Juneau, AK and Wake Island; the installation and operation of communications 

and telemetry equipment in Cordova, AK; the placement and operation of sensors at 

PMRF; and deployment and operation of the transportable telemetry system at Whidbey 

Island, WA and no environmental impacts have been observed.

Reference: Missile Defense Agency Siting and Operating the Forward-Based X-Band 

Transportable (FBX-T) Radar in Japan Environmental Review, September 2006

Numerous proposed activities were analyzed, including the construction and operation of 

an FBX-T radar installation powered using ultra-low sulfur diesel-fueled generators in 

Shariki, Japan. Eleven broad areas of environmental resources were analyzed and MDA 

determined that no significant impacts would occur as a result of generator operations.

MDA has been operating these diesel-fueled generators since building the facility in 

2007. In 2010, the site was switched over to commercial power, with the generators 

remaining for use as emergency backup generators. At no time has MDA observed any 

environmental impacts from these operations.

Reference: Missile Defense Agency Ballistic Missile Defense System (BMDS) 

Programmatic Environmental Impact Statement, January 2007

The complete spectrum of MDA BMDS test activities were analyzed, including the use 

of diesel-fueled generators to power sensors and support equipment at test ranges around 

the world. Thirteen broad areas of environmental consideration were considered for 

assessing potential impacts and MDA determined that use of these diesel-fueled 

generators and support equipment would not have significant environmental effects on a 

programmatic basis. 

MDA has conducted at least four tests every year at locations around the world and no 

environmental impacts resulting from the use of diesel-fueled generators or support 

equipment have been observed.

Reference: Missile Defense Agency Relocatable In-Flight Interceptor 

Communications System Data Terminal #2 at Vandenberg Air Force Base, 

Supplemental Environmental Assessment, November 2007, resulting in a FONSI

Numerous proposed activities were analyzed, including the use of diesel-fueled 

emergency backup generators to power equipment and sensors. Thirteen broad areas of 

environmental consideration were considered for assessing potential impacts and MDA 

determined that no significant impacts would occur as a result of generator operations. 

No environmental impacts have been observed as a result of MDA’s construction and

operation of the IDT #2 and supporting facilities, including the operation of the 

emergency back-up generators at VAFB.

41 October 2013
Reference: REC AN/TPY-2 Radar Deployment at the Ted Stevens Marine Research 

Institute (TSMRI) on the National Oceanic and Atmospheric Administration (NOAA) 

Site in Juneau, Alaska in Support of Flight Test Ground-Based Interceptor (FTG) -04, 

May 2004. Qualifies for Army CATEX (E)(2).

The proposed action among other things was to provide small back-up generators for 

emergency use and that would be periodically exercised according to maintenance 

schedules. Other operational and system components for the AN/TPY-2 would also be 

installed onsite including the auxiliary equipment: Antenna Equipment Unit, Cooling 

Equipment Unit and Electrical Equipment Unit.

Reference: AF 813 Temporary Use of Transportable Telemetry Equipment at 

Eareckson AFS in support of Flight Test 04-5, August 2005. Qualifies for Air Force 

CATEX A2.3.12.

The proposed action included among other things the installation and use of two 60 KW 

diesel electric generators with double-walled fuel tanks, and two Connex trailers, one for 

TM storage and one for TM equipment and/or general storage.

Reference: AF 813 Beddown of Missile Defense Agency (MDA) Mobile Telemetry 

system at Kaena Point Satellite Tracking Station, December, 2010. Qualifies for 

CATEX AF A2.3.12.

The proposed action included among other things the installation and use of an 

uninterrupted power system and backup generators.

Reference: AF 813 VAFB Re-Route Power Lines to Underground at Launch 

Facilities (LF-02, LF-03, LF-21, LF-23), October 2011. Qualifies for Air Force 

CATEX A2.3.12.

The proposed action included among other things the use of an additional rental generator 

while moving the power lines to underground at the LFs.

42 October 2013
Table B-9.1 Comparative Analysis of MDA CATEX B-9 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Department of Rural Utilities Services

Notes

Applicable 

CATEXs B-9 (e)(2) (f)(15) and (f)(36) A2.3.12 7 CFR, 1794.3

Characteristics of 

the Action

Temporary installation and use of electric generators and 

operational support equipment (e.g., communication vans with 

integrated generators) set up on previously disturbed/used area 

(dirt, gravel, or concrete/asphalt pad) several weeks or months 

prior to BMDS test event to provide either primary or back-up 

power/support during BMDS test event. Equipment can be 

used for 1-4 hours a day prior to a test event and run full-time 

through completion of the actual test event, which typically

only lasts 4-12 hours, but could be repeated if the test was 

postponed to a back-up day. Equipment is retrograded within 

several weeks of completion of BMDS test events.

Limited site preparations (e.g., grading, filling, trenching, etc.) 

if any, are conducted; spill containment barriers are used to 

contain fuel spills and coolant leaks. Temporary fencing, 

lightning protection systems, and lighting would be installed 

per local requirements to minimize “shine.”

Wiring can either lie on ground or be in conduit; if site 

conditions and time permits, cabling can be placed in shallow 

trenches dug in previously disturbed areas and utility 

easements.

Diesel fuel provided by installation or approved contractor and 

conforms to air permit and local requirements (e.g., ultra low 

sulfur fuel).

Installation and operation of equipment is confined to host 

installation (or in extremely limited instances, private property 

where similar actions are permitted).

Proposed action is limited to 

acquisition, installation, and operation 

of utility and communication systems, 

mobile antennas, data processing cable 

and similar electronic equipment that 

use existing right-of-way, easement, 

distribution systems, and/or facilities 

(REC required).

MDA has extensive experience working 

at U.S. Army installations such as the 

Ronald Reagan Test Site, USAKA; 

WSMR, NM; Redstone Arsenal, AL; 

Fort Greely, AK; Fort Drum, NY; and 

Fort Belvoir, VA.

(f)(15) Proposed action is limited to 

modification of existing systems or 

equipment when the environmental 

effects will remain substantially the 

same and the use is consistent with 

applicable regulations.

(f)(36) Proposed action is limited to 

acquisition, installation, and operation 

of utility (e.g., water, sewer, electrical) 

and communication systems (e.g., data 

processing cable and similar electronic 

equipment) which use existing rights of 

way, easements, distribution systems, 

and/or facilities.

MDA has extensive experience working 

at U.S. Navy installations such as 

PMRF, HI; Point Mugu Sea Range, CA; 

San Nicolas Island, CA; and Dahlgren 

Naval Base, VA.

Proposed action is limited installing, 

operating, modifying, and routinely 

repairing and replacing utility and 

communications systems, data 

processing cable, and similar electronic 

equipment that use existing rights of 

way, easements, distribution systems, or 

facilities.

MDA has extensive experience working 

at U.S. Air Force Installations such as 

Vandenberg AFB, CA; Edwards AFB, 

CA; Wake Island; Clear AFS, AK; 

Elmendorf AFB, AK; Eareckson AFS, 

AK; and Schriever AFB, CO.

Proposed action is limited to the 

construction of standby diesel electric 

generators (one megawatt or less total 

capacity) and associated facilities, for 

the primary purpose of providing 

emergency power, at an existing 

applicant headquarters or district office, 

telecommunications switching site, or 

an industrial, commercial or agricultural 

facility served by the applicant.

Temporary installation and use limits the 

potential temporal effects of the proposed 

action.

Limiting proposed action to areas that are 

previously disturbed/used minimizes the 

potential to disturb sensitive environmental 

and/or cultural resources. 

Relying on limited site preparation minimizes

potential impacts from construction activities.

Use of spill containment barriers prevents 

contamination of soil in the event of a fuel 

spill.

Temporary fencing keeps unprotected 

populations from entering the site.

Requiring lighting to meet local 

requirements/restrictions prevents 

unnecessary “shine” and potential impact to 

night time behavior.

Limiting trenching to shallow depths in 

established easements minimizes the potential 

to disturb sensitive environments and cultural 

resources.

Applying permit conditions and local 

requirements minimizes potential air impacts.

Methods of 

Implementing the 

Action

Obtain test plan and Continuity of Operations (CONOPs) from 

MDA test proponent.

Work with host installation or property owner to find suitable 

location and permission to install and operate equipment.

Work with host installation or property owner to identify 

applicable laws, regulations, and SOPs.

Work with host installation or property owner to either review 

existing documentation and/or prepare necessary NEPA 

documentation.

Work with host installation or property owner to conduct any 

required site preparation activities.

Work with host installation or property owner to conduct any 

required coordination with Federal and state agencies.

Deploy equipment to site, install, test, and operate equipment 

per Test CONOPs. 

Coordinate with installation staff to

identify applicable laws, regulations, 

management plans, SOPs, and existing 

areas with known natural and/or cultural 

resources and/or environmental 

contamination.

Coordinate with installation staff to 

either review existing documentation 

and/or prepare necessary NEPA 

documentation.

Conduct any required coordination with 

Federal and state agencies.

Same Same Similar, except that proposed action is 

intended for short-term operations over

the life of the facility.

Use of diesel-fueled generators and 

operational support equipment at host 

installation and test ranges is a usual and 

customary activity, which conforms to the 

installation/range’s Master Plan.

43 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Department of Rural Utilities Services Notes

Record generator run time and fuel usage (as required).

Retrograde equipment and restore site to original condition (or 

agreed upon condition – e.g., leaving behind grounding grids or 

sound barriers).

Frequency of the 

Actions

Generally one time. However, at larger installations, MDA 

could conduct up to two tests/year at any given location.

MDA is long-standing range customer

and our test events are built into the host 

installation/range operations and test 

schedule. Test installations/ranges are 

managed to run at optimum capacity, 

year round, to maintain required staff 

and equipment.

Same Same Periodic, routine testing and emergency 

use. Similar to MDA uses during 

extended waiting periods when test 

activities are delayed.

Typical range operations subject to conditions 

of installation’s regulatory permits and master 

schedule.

Applicable 

Regulations

NEPA, CAA, U.S. EPA Tier 4 emissions regulations, and 

applicable state regulations.

Same, plus UES Same Same Same

Applicable SOPs Installation/Manufacturer specific Same Same Same Same

Timing and 

Context

Generator and/or support equipment used to support BMDS 

test events and could occur any time of the year. Equipment, 

many times, is tactical or operational equipment and is in short 

supply; therefore, it is moved to other locations as needed.

BMDS test events are typically conducted at host installations 

designed to conduct same types of testing. MDA relies on 

installation’s infrastructure and sensors. However, some 

BMDS components being tested are either the specific system 

under test or are brought in to augment those operated by the 

range/installation. If adequate power is available from host 

installation, MDA will use available power. However, some 

systems require their own power. For example, the standalone 

tactical radar systems (e.g., the AN/TPY-2 radar) can either use 

available power or generator power; where as a missile 

interceptor and radar weapon system (e.g., THAAD or PAC-3 

systems) requires the use of their own tactical generators. 

Other times, for test reliability purposes, the system under test 

will run off of host power (or shore power) and use tactical or 

operational generators as backup. 

On rare occasions a radar or sensor will be required to be sited 

and operated on property other than a Military Service site. 

The same SOPs, requirements, procedures apply.

Same Same Same Permanent

Extraordinary 

Circumstances

BMDS test events can be delayed and equipment could be left 

at a test site for a while longer (e.g., several months) than 

anticipated.

Same Same Same Extended periods of outage requiring 

excessive use.

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no significant 

impacts from generator or support equipment use beyond those 

resulting from accidental spills of coolants or fuel during 

fueling activities. Potential impacts are mitigated using spill 

containment equipment and fueling SOPs. Contaminated 

media is removed and treated IAW applicable regulations.

Same Same Same Unknown (but expected to be similar)

44 October 2013
Table B-9.2 Comparative Analysis of MDA CATEX B-9 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Theater High Altitude 

Area Defense (THAAD) 

Pacific Test Flights 

Environmental Assessment, 

December 2002, FONSI 

Signed

Ground-Based Midcourse 

Defense (GMD) Extended 

Test Range (ETR) 

Environmental Impact 

Statement, July 2003

MDA Ground-Based 

Midcourse Defense 

Northeast Remote In-Flight 

Interceptor 

Communication System 

Data Terminal 

Environmental Assessment, 

May 2004, FONSI Signed

MDA Mobile Launch 

Platform (MLP) 

Environmental Assessment, 

June 2004, FONSI Signed

Mobile Sensors 

Environmental Assessment, 

September 2005, FONSI 

Signed

MDA Siting and Operating 

the Forward-Based X-Band 

Transportable (FBX-T) 

Radar in Japan 

Environmental Review, 

September 2006

Missile Defense Agency 

Ballistic Missile Defense 

System (BMDS) 

Programmatic 

Environmental Impact 

Statement, January 2007

MDA Relocatable InFlight Interceptor 

Communications System 

Data Terminal (IDT) #2 at 

Vandenberg Air Force 

Base, Supplemental 

Environmental 

Assessment, November 

2007, FONSI Signed

Applicable 

CATEXs B-9

Characteristics 

of the Action

Temporary installation and use 

of electric generators and 

operational support equipment 

(e.g., communication vans with 

integrated generators) set up on 

previously disturbed / used area 

(dirt, gravel, or concrete/asphalt 

pad) several weeks or months 

prior to BMDS test event to 

provide either primary or backup 

power / support during BMDS 

test event. Equipment can be 

used for 1-4 hours a day up to 

24/7 during the actual BMDS 

test event, which only lasts 4-12 

hours. Equipment is retrograded 

within several weeks of 

completion of BMDS test event.

Limited site preparations (e.g., 

grading, filling, trenching, etc.) 

if any), if any, are conducted; 

spill containment barriers are 

used to contain fuel spills and 

coolant leaks. Temporary 

fencing, lightning protection 

systems, and lighting would be 

installed per local requirements 

to minimize “shine.”

Wiring can either lie on ground 

or be in conduit; if site 

conditions and time permits, 

cabling can be placed in shallow 

trenches dug in previously 

disturbed areas and utility 

easements.

Diesel fuel provided by 

installation and conforms to air 

permit and local requirements 

(e.g., ultra low sulfur fuel).

Installation and operation of 

equipment is confined to host 

installation (or in extremely 

limited instances, private 

property where similar actions 

are permitted).

Numerous proposed 

activities were analyzed, 

including the operation of 

THAAD prime power units, 

each of which provides >1.3 

megawatts of power using 

multiple diesel-fueled 

generators. 

Numerous proposed activities 

were analyzed, including the 

use of diesel-fueled power 

generators to support 

transportable radars, 

communications equipment, 

and various supporting 

equipment. 

Numerous proposed activities 

were analyzed, including the 

installation and operation of 

emergency diesel generators 

and support equipment. 

Between generator testing 

and operations during power 

outages, it is estimated that 

the onsite backup generators 

would operate for less than 

500 hours per year, every 

year for the life of the IDT 

ISFAC. 

Numerous proposed activities 

were analyzed, including the 

use of diesel-fueled 

generators to power BMDS

test equipment and sensors. 

Numerous proposed activities 

were analyzed, including the 

use of a wide range in size of 

diesel-fueled generators to 

power BMDS test sensors 

and supporting equipment. 

The EA stated that emissions 

associated with the 

generators would impact 

local air quality; however, 

even if the emissions 

occurred within the most 

stringent nonattainment area 

associated with the landbased test sites (a severe 

nonattainment area for 

ozone), the emission values 

would most likely not exceed 

the de minimis emission 

levels. In addition, because 

the location where the mobile 

land-based sensors and their 

associated generators would 

be used are typically within 

active test ranges, sensitive 

populations (children, 

elderly) or locations (schools, 

population centers) would not 

be located near such emission 

sources. The EA also stated 

that MDA would be required 

to notify regulators, obtain all 

necessary permits, and in 

some cases complete an Air 

Conformity Applicability 

Analysis. 

Numerous proposed activities 

were analyzed, including the 

construction and operation of 

an FBX-T radar installation 

powered using ultra-low 

sulfur diesel-fueled 

generators in Shariki, Japan. 

The complete spectrum of 

MDA BMDS test activities 

were analyzed, including the 

use of diesel-fueled 

generators to power sensors 

and supporting equipment at 

test ranges around the world. 

Numerous proposed 

activities were analyzed, 

including the use of dieselfueled emergency backup 

generators to power 

equipment and sensors. 

45 October 2013
Benchmarking 

Categories MDA Theater High Altitude 

Area Defense (THAAD) 

Pacific Test Flights 

Environmental Assessment, 

December 2002, FONSI 

Signed

Ground-Based Midcourse 

Defense (GMD) Extended 

Test Range (ETR) 

Environmental Impact 

Statement, July 2003

MDA Ground-Based 

Midcourse Defense 

Northeast Remote In-Flight 

Interceptor 

Communication System 

Data Terminal 

Environmental Assessment, 

May 2004, FONSI Signed

MDA Mobile Launch 

Platform (MLP) 

Environmental Assessment, 

June 2004, FONSI Signed

Mobile Sensors 

Environmental Assessment, 

September 2005, FONSI 

Signed

MDA Siting and Operating 

the Forward-Based X-Band 

Transportable (FBX-T) 

Radar in Japan 

Environmental Review, 

September 2006

Missile Defense Agency 

Ballistic Missile Defense 

System (BMDS) 

Programmatic 

Environmental Impact 

Statement, January 2007

MDA Relocatable InFlight Interceptor 

Communications System 

Data Terminal (IDT) #2 at 

Vandenberg Air Force 

Base, Supplemental 

Environmental 

Assessment, November 

2007, FONSI Signed

Applicable 

CATEXs B-9

Methods of 

Implementing 

the Action

Obtain test plan and CONOPs 

from MDA test proponent.

Work with host installation or 

property owner to find suitable 

location and permission to 

install and operate equipment.

Work with host installation or 

property owner to identify 

applicable laws, regulations, and 

SOPs.

Work with host installation or 

property owner to either prepare 

necessary NEPA documentation.

Work with host installation or 

property owner to conduct any 

required site preparation 

activities.

Deploy equipment to site, 

install, test, and operate 

equipment per Test CONOPs. 

Record generator run time and 

fuel usage (as required).

Retrograde equipment and 

restore site to original condition 

(or agreed upon condition – e.g., 

leaving behind grounding grids 

or sound barriers).

Same Same Permanent installation and 

operation.

Same Same Permanent installation and 

operation.

Same Permanent installation and 

operation.

Frequency of the 

Actions

Generally one time. However, 

at larger installations, MDA 

could conduct up to two 

tests/year at any given location.

Up to two flight tests a year. Up to two flight tests a year. 24 hours/7 days a week 

operations.

Up to four flight tests per 

year.

Up to four flight tests per 

year.

24 hours/7 days a week 

operations.

Variable. 24 hours/7 days a week 

operations.

Applicable 

Regulations

NEPA, CAA, EPA Tier 4 

emissions regulations, and 

applicable state regulations.

Same Same Same Same Same Same, Final Governing 

Standards

Same Same

Applicable SOPs Installation/Manufacturer 

specific

Same Same Same Same Same Same Same Same

Timing and 

Context

Generator and/or support 

equipment used to support 

BMDS test events could occur 

any time of the year. 

Equipment, many times, is 

Same Same 24 hours/7 days a week 

operations.

Same Same 24 hours/7 days a week 

operations.

Variable 24 hours/7 days a week 

operations.

46 October 2013
Benchmarking 

Categories MDA Theater High Altitude 

Area Defense (THAAD) 

Pacific Test Flights 

Environmental Assessment, 

December 2002, FONSI 

Signed

Ground-Based Midcourse 

Defense (GMD) Extended 

Test Range (ETR) 

Environmental Impact 

Statement, July 2003

MDA Ground-Based 

Midcourse Defense 

Northeast Remote In-Flight 

Interceptor 

Communication System 

Data Terminal 

Environmental Assessment, 

May 2004, FONSI Signed

MDA Mobile Launch 

Platform (MLP) 

Environmental Assessment, 

June 2004, FONSI Signed

Mobile Sensors 

Environmental Assessment, 

September 2005, FONSI 

Signed

MDA Siting and Operating 

the Forward-Based X-Band 

Transportable (FBX-T) 

Radar in Japan 

Environmental Review, 

September 2006

Missile Defense Agency 

Ballistic Missile Defense 

System (BMDS) 

Programmatic 

Environmental Impact 

Statement, January 2007

MDA Relocatable InFlight Interceptor 

Communications System 

Data Terminal (IDT) #2 at 

Vandenberg Air Force 

Base, Supplemental 

Environmental 

Assessment, November 

2007, FONSI Signed

Applicable 

CATEXs B-9

tactical or operational equipment 

and is in short supply; therefore, 

it is moved to other locations as 

needed.

BMDS test events are typically

conducted at host installations 

designed to conduct same types 

of testing. MDA relies on 

installation’s infrastructure and 

sensors. However, some BMDS 

components being tested are 

either the specific system under 

test or are brought in to augment 

those operated by the 

range/installation. If adequate 

power is available from host 

installation, MDA will use 

available power. However, 

some systems require their own 

power. For example, the stand

alone tactical radar systems 

(e.g., the AN/TPY-2 radar) can 

either use available power or 

generator power; where as a 

missile interceptor and radar 

weapon system (e.g., THAAD or 

PAC-3 systems) requires the use 

of their own tactical generators. 

Other times, for test reliability 

purposes, the system under test 

will run off of host power (or 

shore power) and use tactical or 

operational generators as 

backup. 

Extraordinary 

Circumstances

BMDS test events can be 

delayed and equipment could be 

left at a test site for a while 

longer (e.g., several months) 

than anticipated.

Same Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, 

MDA knows of no significant 

impacts from generator or 

support equipment use beyond 

those resulting from accidental 

spills of coolants or fuel during 

fueling activities. Potential 

impacts are mitigated using spill 

containment equipment and 

fueling SOPs. Contaminated 

Over the course of 6 years, 

MDA conducted a-half 

dozen THAAD tests at the 

Pacific Missile Range 

Facility and no 

environmental impacts were 

observed as documented in 

mitigation monitoring 

reports.

Since the construction of the 

GMD ETR, MDA has 

conducted an average of onetwo flight tests a year and 

operated the Sea-Based XBand Radar nearly 

continuously and no 

environmental impacts were 

observed.

The ISFAC facility has not 

yet been built; therefore, the 

FONSI cannot yet be 

substantiated at this time.

The MLP has been used on 

two to five missions per year 

since 2005 and no 

environmental impacts have 

been observed.

MDA has conducted 

numerous test activities using 

mobile sensors and their 

supporting diesel-fueled 

generators, including the 

operation of the AN/TPY-2 

radar in Juneau, AK and 

Wake Island, the installation 

and operation of 

communications and 

MDA has been operating 

these diesel-fueled generators 

since building the facility in 

2007. In 2010, the site was 

switched over to commercial 

power, with the generators 

remaining for use as 

emergency backup 

generators. At no time has 

MDA observed any 

MDA has conducted at least 

four tests every year at 

locations around the world 

and no environmental 

impacts resulting from the 

use of diesel-fueled 

generators or support 

equipment have been 

observed.

No environmental impacts 

have been observed as a 

result of MDA’s 

construction and operation 

of the IDT #2 and 

supporting facilities, 

including the operation of 

the emergency backup 

generators at VAFB.

47 October 2013
Benchmarking 

Categories MDA Theater High Altitude 

Area Defense (THAAD) 

Pacific Test Flights 

Environmental Assessment, 

December 2002, FONSI 

Signed

Ground-Based Midcourse 

Defense (GMD) Extended 

Test Range (ETR) 

Environmental Impact 

Statement, July 2003

MDA Ground-Based 

Midcourse Defense 

Northeast Remote In-Flight 

Interceptor 

Communication System 

Data Terminal 

Environmental Assessment, 

May 2004, FONSI Signed

MDA Mobile Launch 

Platform (MLP) 

Environmental Assessment, 

June 2004, FONSI Signed

Mobile Sensors 

Environmental Assessment, 

September 2005, FONSI 

Signed

MDA Siting and Operating 

the Forward-Based X-Band 

Transportable (FBX-T) 

Radar in Japan 

Environmental Review, 

September 2006

Missile Defense Agency 

Ballistic Missile Defense 

System (BMDS) 

Programmatic 

Environmental Impact 

Statement, January 2007

MDA Relocatable InFlight Interceptor 

Communications System 

Data Terminal (IDT) #2 at 

Vandenberg Air Force 

Base, Supplemental 

Environmental 

Assessment, November 

2007, FONSI Signed

Applicable 

CATEXs B-9

media is removed and treated 

IAW applicable regulations.

telemetry equipment in 

Cordova, AK, the placement 

and operation of sensors at 

PMRF, and deployment and

operation of the transportable 

telemetry system at Whidbey 

Island, WA and no 

environmental impacts have 

been observed.

environmental impacts from 

these operations.

48 October 2013
B-10. Routine movement, handling, use and distribution of materials, including hazardous 

materials or wastes that are moved, handled, or distributed in accordance with 

applicable regulations, such as Resource Conservation and Recovery Act (RCRA), 

Occupational Safety and Health Administration (OSHA) and Hazardous Materials 

Transportation Act (HMTA).

The Team examined the various activities undertaken throughout the Agency to determine the 

extent to which materials contemplated by this CATEX were procured, transported, distributed, 

used, and stored during the normal course of operations. A number of these materials are 

considered to be hazardous materials, including fuels for vehicles and equipment, solid and 

liquid propellants, and oxidizers. The Team found that actions of a similar nature, scope, and 

intensity were quite common throughout the Agency in both operational and test activities. The 

majority of hazardous materials procured, transported, distributed, used, and stored were found 

to be commercially available materials.

The Team determined that the hazardous materials contemplated by this CATEX are transported 

and handled in accordance with applicable U.S. Department of Transportation (U.S. DOT) and 

Military Service regulations ((including DoD 4500.9-R, Defense Transportation Regulation, Part 

2, Chapter 204 - Hazardous Materials and Air Force Manual, AFMAN 24-204 IP (Interservice)): 

Preparing Hazardous Materials for Military Air Shipments, 15 April 2007) to meet a variety of 

stringent requirements designed to protect human health and safety and the quality of the human 

environment. The Team also found actions of a similar nature, scope, and intensity was

performed in compliance with Federal, tribal, state, or local law and/or regulatory policy. 

This CATEX is supported by administrative records from MDA mission activities developed 

through the NEPA process. The Team noted other Federal agencies, in particular Services, have 

CATEXs for similar activities sufficiently descriptive that it could be determined they included a 

much broader range of activities and encompassed activities of generally greater scope and 

intensity than any in MDA. The volume of materials procured by other Service agencies dwarf 

those of MDA. In addition, MDA like all Federal agencies, with very few exceptions, must meet 

the same requirements to protect the environment. 

As documented in Table B-10.1 and B-10.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

49 October 2013
4) Extraordinary circumstances associated with its application is absent; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(h) (4) Routine management, to include transportation, distribution, use, storage, 

treatment, and disposal of solid waste, medical waste, radiological and special hazards 

(for example, asbestos, PCBs, lead-based paint, or unexploded ordnance), and/or 

hazardous waste that complies with EPA, Army, or other regulatory agency requirements. 

This CATEX is not applicable to new construction of facilities for such management 

purposes.

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(16) Routine movement, handling and distribution of materials, including hazardous 

materials/wastes that are moved, handled, or distributed in accordance with applicable 

regulations.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.28. Routine transporting of hazardous materials and wastes in accordance with 

applicable Federal, state, interstate, and local laws.

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(24) Routine movement of personnel and equipment, and the routine movement, 

handling, and distribution of non-hazardous materials and waste in accordance with 

applicable regulations.

50 October 2013
Missile Defense Agency Environmental Reviews

Reference: Exo-atmospheric Kill Vehicle (EKV) Final Assembly and Checkout 

Operations (FACO) at Redstone Arsenal, Alabama Supplemental Environmental 

Assessment, March 2000, resulting in a FONSI

This EA analyzed the environmental impacts of three proposed main activities, one of 

which was transportation of the completed EKVs to the existing National Missile 

Defense interceptor Assembly, Test, and Checkout (AT&C) facility for final integration. 

The EKV is the missile payload that impacts and destroys an incoming missile. The 

EKV is transported to the FACO facility for final assembly and checkout prior to 

transport to the launch site.

Unloaded EKV subassemblies and pre-loaded bi-propellant tanks would be shipped to the

EKV FACO facility in accordance with all appropriate DOT approved procedures. 

The resulting environmental analysis showed no significant impacts would occur from 

the proposed EKV FACO activities. No adverse environmental impacts resulting from 

hazardous material handling and transport have been recorded during EKV FACO 

operations.

Reference: Ground-based Midcourse Defense Element Live Fire Test and Evaluation 

(LFT&E) Targets Environmental Assessment, October 2001, resulting in a FONSI

This EA analyzed three main activities, one of which was the transportation of payload 

components to Vandenberg AFB. Deuterium fluoride (DF) seedant is the fuel used to 

launch the missile and would be shipped directly to Vandenberg AFB from the 

manufacturer by commercial carrier. Only enough seedant for two missile flights would 

be shipped to Vandenberg AFB at a time.

The re-entry vehicle (RV) and payload with high explosive (HE) would be transported to 

Vandenberg AFB from Lawrence Livermore National Laboratory/Sandia National 

Laboratories facilities by the Department of Energy Safe Secure Transport or by 

commercial carrier. The RV and payload would be stored in an approved facility at 

Vandenberg AFB until integrated into the target missile. Seedant filling equipment 

would be transported by commercial carrier to Missile Assembly Building (MAB) 1819. 

All transportation of the seedant and HE within the continental United States would be

performed in accordance with U.S. DOT and U.S. Army approved explosive safety and 

hazardous material regulations and routing. The seedant and HE would be transported in 

U.S. DOT-approved shipping containers. Appropriate safety measures would be followed 

during transportation of the seedant and HE as required by U.S. DOT and as described in 

the Bureau of Explosives (BOE) Tariff No. BOE 6000-l, Hazardous Materials 

Regulations of the Department of Transportation. For aircraft transportation, Federal 

Aviation Administration (FAA) and/or applicable U.S. Air Force safety regulations 

would be followed.

51 October 2013
Implementation of the proposed action would result in negligible impacts to resources on 

Vandenberg AFB. All activities would be in compliance with applicable Federal, state 

and local regulations and requirements. The resulting environmental analysis showed no 

significant impacts would occur. 

All activities have been in compliance with applicable Federal, state and local regulations 

and requirements and no adverse environmental impacts resulting from hazardous 

material handling and transport have been recorded or observed during these operations.

Reference: Liquid Propellant Missile (LPM) Site Preparation and Launch 

Environmental Assessment, July 2002, resulting in a FONSI

This EA analyzed two LPMs launched from a new ground surface site at Vandenberg 

AFB. The analysis looked at the environmental impacts of transporting the missile and 

liquid propellant to and storage at Vandenberg AFB. 

The main fuel for the missile was coal tar distillate. For the two proposed launches, 

approximately 300 gallons of main fuel would be required per launch. Approximately 

500 gallons of the oxidizer, inhibited red fuming nitric acid, would be required per 

launch. Also, approximately 10 gallons of initiator fuel would be used during each 

launch.

The missile would be transported to the propellant loading site, approximately one mile 

north of the launch site, for propellant loading operations. The propellants would be 

transported from the Hypergolic Storage Facility to the propellant loading area one day 

prior to fueling operations. When the main fuel and oxidizer have been loaded into the 

missile, the missile would be lowered onto the Mobile Launcher, which would then 

proceed to the launch area.

All activities would be in compliance with applicable federal, state and local regulations 

and requirements. The resulting environmental analysis showed no significant impacts 

would occur from the proposed transportation, LPM site preparation and launch 

activities. No environmental impacts resulting from hazardous material handling and 

transport have been recorded during these operations.

Reference: Ground-Based Midcourse Defense (GMD) Initial Defensive Operations 

Capability (IDOC) at Vandenberg Air Force Base Environmental Assessment, August 

2003, resulting in a FONSI

Numerous proposed activities were analyzed, including transportation of GBI missile 

boosters, payloads and support equipment by air or over-the road common carrier truck 

from U.S. Government storage depots or contractor facilities to Vandenberg AFB. All 

shipping would be conducted in accordance with applicable USAF, FAA and DOT

regulations. Transportation of hazardous materials would be in accordance with DOT

regulations for interstate shipment of hazardous materials found in 49 CFR parts 100-

52 October 2013
199. Applicable safety regulations would be followed in the transport, receipt, storage 

and handling of hazardous materials. 

Thirteen broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that no significant impacts would occur as a 

result of handling and transporting GBIs and support equipment. No environmental 

impacts resulting from hazardous material handling and transport have been recorded 

during these operations.

Reference: Missile Defense Agency Courtland Target Assembly Facility 

Environmental Assessment, October 2006, resulting in a FONSI

A portion of the Proposed Action would entail target components and boosters being 

transported via truck and/or rail to the Courtland Facility from locations that could 

include, but would not be limited to: Alliant Techsystems (ATK) in Ogden Utah; Orbital 

Sciences Corporation, Chandler, Arizona; Stennis Space Center, Mississippi; Strategic 

Weapons Facility Pacific (SWFPAC), Bangor, Washington; Hill AFB, Utah; Promontory 

Point Utah; Camp Navajo, Arizona; and the Lockheed Martin Huntsville Target Missile 

systems (TMS), Alabama. Transport of boosters and components would comply with all 

DOT requirements for shipping of explosive materials.

A conservative analysis would assume that under surge assembly conditions, a maximum 

of 20 targets would be assembled at Courtland per year. Under these conditions, a total 

of 80 roundtrip shipments by truck or railroad would be required assuming that each 

booster would be shipped individually by truck and/or rail to the Courtland Facility. A 

total of 160 trips would be made, although only 80 would be carrying hazardous material, 

as the returning transport vehicle would be assumed to be empty. 

Twelve broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that no significant impacts would occur as a 

result handling and transporting target components and boosters. No environmental 

impacts resulting from hazardous material handling and transport have been recorded 

during these operations.

53 October 2013
Table B-10.1 Comparative Analysis of MDA CATEX B-10 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard

Notes

Applicable 

CATEXs B-10 (h)(4) (f)(16) A2.3.28 (24)

Characteristics 

of the Action

Routine movement, handling, use, and distribution of 

materials, including hazardous materials/wastes that are 

moved, handled, or distributed in accordance with 

applicable regulations, such as RCRA, OSHA and 

HMTA.

Volumes of hazardous materials/wastes are generally 

less than the Military Services. Types of substances 

generally include batteries and solid or liquid propellant 

and/or oxidizers for missiles, hydrazine for some divertaltitude control (DAC) units (in interceptor missiles), 

diesel fuel for generators, antifreeze, maintenance 

products, cleaning supplies, and office supplies. Small 

amounts of explosives (e.g., squibs) are transported and 

integrated in either missile bodies or air launch target 

pallets.

Solid propellants are integrated in the missile during 

manufacturing, liquid propellants are transported in 

specialized containers and loaded into the missile at the 

test site; DACs are filled with hydrazine at the 

manufacturing location; and batteries/squibs are 

generally deployed at test locations; all are transported 

IAW Federal, state, and the Military Service’s 

requirements.

Maintenance activities consume paint, oil and grease, 

small amounts of solvents or glues/mastic. Office and 

cleaning products are non-hazardous whenever feasible 

in keeping with MDA’s Green Procurement Program.

Proposed action is limited to routine 

management, to include transportation, 

distribution, use, storage, treatment, and 

disposal of solid waste, medical waste, 

radiological and special hazards (for 

example, asbestos, PCBs, lead-based 

paint, or unexploded ordnance), and/or 

hazardous waste that complies with 

EPA, Army, or other regulatory agency 

requirements. This CATEX is not 

applicable to new construction of 

facilities for such management 

purposes.

MDA has extensive experience working 

at U.S. Army installations such as the 

Ronald Reagan Test Site, USAKA; 

WSMR, NM; Redstone Arsenal, AL; 

Fort Greely, AK; Fort Drum, NY; and 

Fort Belvoir, VA.

Proposed action is limited to routine 

movement, handling and distribution of 

materials, including hazardous 

materials/wastes that are moved, 

handled, or distributed in accordance 

with applicable regulations.

MDA has extensive experience working 

at U.S. Navy installations such as 

PMRF, HI; Point Mugu Sea Range, CA; 

San Nicolas Island, CA; and Dahlgren 

Naval Base, VA.

Proposed action is limited to routine 

transporting of hazardous materials 

and wastes in accordance with 

applicable Federal, state, interstate, 

and local laws.

MDA has extensive experience 

working at U.S. Air Force 

Installations such as Vandenberg 

AFB, CA; Edwards AFB, CA; Wake 

Island; Clear AFS, AK; Elmendorf 

AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

Proposed action is limited to routine 

movement of personnel and 

equipment, and the routine movement, 

handling, and distribution of nonhazardous materials and waste in 

accordance with applicable 

regulations.

Strict and detailed regulations govern 

these activities.

Methods of 

Implementing 

the Action

Work with host installation or property owner to 

identify applicable laws, regulations, management plans, 

and SOPs.

Work with host installation or property owner to obtain 

required permits and record and report usage and 

disposal.

Work with host installation or property owner to either 

review existing documentation and/or prepare necessary 

NEPA documentation.

Work with host installation or property owner to 

conduct any required coordination with Federal and 

state agencies.

Ensure materials are transported, stored and handled in 

appropriate manner.

Coordinate with installation staff to

identify applicable laws, regulations, 

management plans, SOPs.

Installation staff obtains required 

permits and record and report usage and 

disposal.

Installation staff to either reviews

existing documentation and/or prepares

necessary NEPA documentation.

Conduct any required coordination with 

Federal and state agencies.

Ensure materials are transported, stored 

and handled in appropriate manner.

Same Same Similar All these activities are conducted 

according to detailed regulations that 

are fundamentally consistent across 

Federal agencies, although state 

regulations may differ.

54 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard Notes

Frequency of the 

Actions

Majority of MDA’s hazardous material handling and 

transport activities usually occurs in conjunction with 

missile assembly and transport related to test events. 

Amounts of hazardous materials are typically not large, 

especially compared to the large amounts of fuel and 

hazardous materials used on a daily basis by the 

Military Services. 

Greater Greater Greater Unknown Typical range operations are subject to 

conditions of host installation’s 

regulatory permits and management 

plans.

Applicable 

Regulations

NEPA, CERCLA, RCRA, CWA, CAA HMTA and 

other applicable Federal and state regulations, DoD and 

Military Service requirements, and industry standards.

Same Same Same Same

Applicable SOPs Installation specific, but most are consistent among 

installations, because of proscriptive nature of Federal 

and state regulations.

Same Same Same Same

Timing and 

Context

MDA use, transport, and disposal are mostly in 

conjunction with test activities. Maintenance activities 

regularly occur per maintenance schedules or when 

situations require attention. Office products (e.g., 

printer toner) and cleaning products are used every day.

Continuous over time at high levels 

relative to MDA.

Continuous over time at high levels 

relative to MDA.

Continuous over time at high levels 

relative to MDA.

Continuous over time at high levels 

relative to MDA.

Extraordinary 

Circumstances

The large-scale movement of hazardous materials or 

generation of hazardous waste is unlikely, but could 

potentially occur if an entire weapon system were to be 

decommissioned.

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known 

significant impacts from these types of operations. 

Same Same Same Same

55 October 2013
Table B-10.2 Comparative Analysis of MDA CATEX B-10 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Exo-atmospheric Kill Vehicle (EKV) Final Assembly and Checkout 

Operations (FACO) at Redstone 

Arsenal, Alabama Supplemental 

Environmental Assessment, March 

2000, FONSI Signed

Ground-based Midcourse Defense 

Element Live Fire Test and 

Evaluation (LFT&E) Targets 

Environmental Assessment, October 

2001, FONSI Signed

Liquid Propellant Missile (LPM) Site 

Preparation and Launch 

Environmental Assessment, July 

2002, FONSI Signed

Ground-Based Midcourse Defense 

(GMD) Initial Defensive Operations 

Capability (IDOC) at Vandenberg 

Air Force Base Environmental 

Assessment, August 2003, FONSI 

Signed

Missile Defense Agency Courtland 

Target Assembly Facility 

Environmental Assessment, October 

2006, FONSI Signed Applicable 

CATEXs B-10

Characteristics of 

the Action

Routine movement, handling, use, and 

distribution of materials, including 

hazardous materials/wastes that are moved, 

handled, or distributed in accordance with 

applicable regulations, such as RCRA, 

OSHA and HMTA.

Volumes of hazardous materials/wastes are 

generally less than the Military Services. 

Types of substances generally include 

batteries and solid or liquid propellant and/or 

oxidizers for missiles, hydrazine for some 

DAC units (in interceptor missiles), diesel 

fuel for generators, antifreeze, maintenance 

products, cleaning supplies, and office 

supplies. Small amounts of explosives (e.g., 

squibs) are transported and integrated in 

either missile bodies or air launch target 

pallets.

Solid propellants are integrated in the 

missile during manufacturing, liquid 

propellants are transported in specialized 

containers and loaded into the missile at the 

test site, DACs are filled with hydrazine at 

the manufacturing location, and 

batteries/squibs are generally deployed at 

test locations; all are transported IAW 

Federal, state, and the Military Services’

requirements.

Maintenance activities consume paint, oil 

and grease, small amounts of solvents or 

glues/mastic. Office and cleaning products 

are non-hazardous whenever feasible in 

keeping with MDA’s Green Procurement 

Program.

The EA analyzed the environmental impacts 

of three proposed main activities, one of 

which would be transportation of the 

completed EKVs to the existing NMD 

interceptorAT&C facility for final 

integration. The EA analyzed transport of 

unloaded EKV subassemblies and preloaded bi-propellant tanks to the EKV 

FACO facility in accordance with all 

appropriate DOT approved procedures. 

The EA analyzed the transport of missile

payload components to Vandenberg VAFB, 

from Lawrence Livermore/ Sandia National 

Laboratories and final storage at VAFB. It 

was planned for the DF seedant to be 

shipped directly to Vandenberg AFB from 

the manufacturer by commercial carrier. 

Only enough seedant for two missile flights 

would be shipped to VAFB at a time. 

This EA analyzed the environmental impacts 

of transporting the missile and liquid 

propellant to and storage at Vandenberg 

AFB. 

The main fuel for the missile was coal tar 

distillate. For the two proposed launches, 

approximately 300 gallons of main fuel 

would be required per launch. 

Approximately 500 gallons of the oxidizer, 

inhibited red fuming nitric acid, would be 

required per launch. Also, approximately 10 

gallons of initiator fuel would be used 

during each launch.

The missile would be transported to the 

propellant loading site, approximately one 

mile north of the launch site, for propellant 

loading operations. The propellants would 

be transported from the Hypergolic Storage 

Facility to the propellant loading area one 

day prior to fueling operations. When the 

main fuel and oxidizer have been loaded into 

the missile, the missile would be lowered 

onto the Mobile Launcher, which would 

then proceed to the launch area.

Numerous proposed activities were 

analyzed, including the transport of GBI 

missile boosters, payloads and support 

equipment by air or over-the-road common 

carrier truck from U.S. Government storage 

depots or contractor facilities to VAFB. All 

shipping would be conducted in accordance 

with applicable USAF, FAA and DOT

regulations. Transportation of hazardous 

materials would be in accordance with DOT 

regulations for interstate shipment of 

hazardous materials found in 49 CFR parts 

100-199. The interceptor would be placed in 

existing Vandenberg AFB facilities for 

assembly and check-out. Applicable safety 

regulations would be followed in the 

transport, receipt, storage and handling of 

hazardous materials. 

A portion of the proposed action would 

entail target components and boosters being 

transported via truck and/or rail to the 

Courtland Facility from locations that could 

include, but would not be limited to: ATK in 

Ogden Utah; Orbital Sciences Corporation, 

Chandler, Arizona; Stennis Space Center, 

Mississippi; SWFPAC, Bangor, 

Washington; Hill AFB, Utah; Promontory 

Point Utah; Camp Navajo, Arizona; and the 

Lockheed Martin Huntsville TMS, Alabama. 

Transport of boosters and components 

would comply with all DOT requirements 

for shipping of explosive materials. 

Methods of 

Implementing the 

Action

Work with host installation or property 

owner to identify applicable laws, 

regulations, management plans, and SOPs.

Work with host installation or property 

owner to obtain required permits and to 

record and report usage and disposal.

Work with host installation or property 

owner to either review existing 

documentation and/or prepare necessary 

NEPA documentation.

Same Same Same Same Same

56 October 2013
Benchmarking 

Categories MDA Exo-atmospheric Kill Vehicle (EKV) Final Assembly and Checkout 

Operations (FACO) at Redstone 

Arsenal, Alabama Supplemental 

Environmental Assessment, March 

2000, FONSI Signed

Ground-based Midcourse Defense 

Element Live Fire Test and 

Evaluation (LFT&E) Targets 

Environmental Assessment, October 

2001, FONSI Signed

Liquid Propellant Missile (LPM) Site 

Preparation and Launch 

Environmental Assessment, July 

2002, FONSI Signed

Ground-Based Midcourse Defense 

(GMD) Initial Defensive Operations 

Capability (IDOC) at Vandenberg 

Air Force Base Environmental 

Assessment, August 2003, FONSI 

Signed

Missile Defense Agency Courtland 

Target Assembly Facility 

Environmental Assessment, October 

2006, FONSI Signed Applicable 

CATEXs B-10

Work with host installation or property 

owner to conduct any required coordination 

with Federal and state agencies.

Ensure materials are transported, stored and 

handled in appropriate manner.

Frequency of the 

Actions

Majority of MDA’s hazardous material 

handling and transport activities usually

occurs in conjunction with missile assembly 

and transport related to test events. 

Amounts of hazardous materials are 

typically not large, especially compared to 

the large amounts of fuel and hazardous 

materials used on a daily basis by the 

Military Services.

Several times per year Enough seedant for two missiles at a time Once per year Several times per year Approximately 20 per year

Applicable 

Regulations

NEPA, CERCLA, RCRA, CWA, CAA, 

HMTA and other applicable Federal and 

state regulations, DoD and Military Service 

requirements, and industry standards.

Same Same Same Same Same

Applicable SOPs Installation specific, but most are consistent 

among installations, because of proscriptive 

nature of Federal and state regulations.

Same Same Same Same Same

Timing and 

Context

MDA use, transport, and disposal are mostly 

in conjunction with test activities. 

Maintenance activities regularly occur per 

maintenance schedules or when situations 

require attention. Office products (e.g., 

printer toner) and cleaning products used 

every day.

Same Same Same Same Same

Extraordinary 

Circumstances

The large-scale movement of hazardous 

materials or generation of hazardous waste is 

unlikely, but could potentially occur if an 

entire weapon system were to be 

decommissioned.

Same Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of 

no known significant impacts from these 

types of operations. 

No significant environmental impacts were 

observed as documented in mitigation 

monitoring reports.

No adverse environmental impacts resulting 

from hazardous material handling and 

transport have been recorded during these 

operations.

No adverse environmental impacts resulting 

from hazardous material handling and 

transport have been recorded during these 

operations.

No adverse environmental impacts resulting 

from hazardous material handling and 

transport have been recorded during these 

operations.

No adverse environmental impacts resulting 

from hazardous material handling and 

transport have been recorded during these 

operations.

57 October 2013
B-11. Routine movement of mobile test assets (such as ships, aircraft, mobile sensors, 

telemetry, etc.) for routine missile defense test and evaluation, for repair, overhaul or 

maintenance, or for home port reassignments where no new support facilities are 

required.

Routine movement of mobile test assets, including but not limited to ships, aircraft, mobile 

sensors, and telemetry, were determined to have no potential for significant environmental 

impacts. Movements of these types of Agency assets are usual and customary activities 

conducted at all host installations, ranges, commercial locations, and military/commercial ports

following standard operating procedures and in accordance with appropriate laws and 

regulations. 

A review of the mission and operational activities conducted by the Services and components 

indicated nearly all operate mobile assets and realign those assets in a similar manner and 

environment as does MDA. However, the frequency and intensity of MDA’s activities are 

significantly lower than that of the Services and components. In addition, this CATEX is 

supported by long-standing use of similar CATEXs by other Federal agencies. The Team 

determined the characteristics of the activities at MDA were no different than those performed 

by the Military Services in general, as well as specifically related to the environment. 

MDA’s sea-based assets are home ported/docked at either Naval Bases or commercial ports. 

They are operated using Executing Agents from the US Navy and they follow the same SOPs, 

regulations, and Navy operating instructions as Navy ships; 

MDA’s air-based assets are based at USAF airfields or commercial airports, but abide by the 

same regulations and requirements as the Services at installations where they are deployed for 

test events. MDA has used the Services CATEXs for these particular activities without 

significant impacts to the environment. The military/commercial locations where MDA has its

home porting/basing activities manage similar activities to those conducted by MDA, only at a 

larger scale, and the Services do so in a greater variety of natural environments. 

Where reassignment home porting/basing is involved, the Team specifically limited this CATEX

to existing operational facilities (e.g., Naval Base, Air Force Base, Army Garrison, commercial 

airport, or port) that have the capacity to accommodate such assets (e.g. Sea-Based X-Band

(SBX) Radar Vessel, MLP, air-borne sensor systems, etc.) or where changes to supporting 

infrastructure would be minor. These limitations were applied to ensure there would be no 

potential for significant environmental impacts contemplated by the application of this CATEX.

Based on this analysis, the Team determined the activities contained in this CATEX should be, 

absent extraordinary circumstances, excluded from further analysis and documentation in an EA

or EIS.

As documented in Table B-11.1 and B-11.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

58 October 2013
extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(11) Routine movement of mobile assets (such as ships and aircraft) for homeport 

reassignments, for repair/overhaul, or to train/perform as operational groups where no 

new support facilities are required.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.31. Relocating a small number of aircraft to an installation with similar aircraft that 

does not result in a significant increase of total flying hours or the total number of aircraft 

operations, a change in flight tracks, or an increase in permanent personnel or logistics 

support requirements at the receiving installation. Repetitive use of this CATEX at an 

installation requires further analysis to determine there are not cumulative impacts. The 

EPF must document application of this CATEX on AF Form 813.

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

4. Operational Actions a. Realignment or initial home porting of mobile assets, including 

vessels and aircraft, to existing operational facilities that have the capacity to 

accommodate such assets or where supporting infrastructure changes will be minor in 

nature to perform as new home ports or for repair and overhaul. Note: If the realignment 

or home porting would result in more than a one for one replacement of assets at an 

59 October 2013
existing facility, then the checklist required for this CATEX must specifically address 

whether such an increase in assets could trigger the potential for significant impacts to 

protected species or habitats before use of the CATEX can be approved. (Checklist and 

CED required).

Missile Defense Agency Environmental Reviews

Reference: Missile Defense Agency Mobile Launch Platform (MLP) Environmental 

Assessment, June 2004, resulting in a FONSI

The EA analyzed the use of the existing MLP to provide a mobile sea-based platform 

from which to test sensors (radars, telemetry, and optical systems), ballistic missile 

targets, and defensive missile interceptors in support of MDA’s mission. The MLP is the 

former USS Tripoli (LPH 10), a converted U.S. Navy Iwo Jima Class Amphibious 

Assault Ship (Helicopter). 

The MLP has no engines for propulsion and would be towed from port to the test event 

location. Either a government-owned contractor-operated or commercial tug would tow 

the MLP from its home port (Mare Island, CA) to specific locations for test events. Postlaunch activities would include transporting the MLP from the test event location to the 

ordnance loading port or home port as appropriate.

Nine broad areas of environmental consideration were considered for assessing potential 

impacts. Because the proposed action involves the use of the MLP as a mobile sea-based 

platform for testing sensors and launching target and interceptor missiles, the majority of 

potential impacts would occur in the ocean. MDA determined that no significant impacts 

to the environment or surrounding populations would occur. 

The MLP has been used two to five missions per year since 2005 and no environmental 

impacts have been observed.

Reference: Mobile Sensors Environmental Assessment, September 2005, resulting in 

a FONSI

This EA analyzed the use of land-based mobile sensors and airborne sensor systems (i.e., 

optical and infrared systems) to provide comprehensive and realistic test surveillance and 

tracking data capabilities in support of the MDA Ballistic Missile Defense System 

(BMDS). 

The proposed airborne sensor systems would be housed in a modified Gulfstream IIB 

aircraft and a modified DC-10 aircraft. Activities associated with the airborne sensor 

systems included among other things flying the airborne sensor systems to test support 

locations; setting up, checking out and performing maintenance on aircraft; flying 

airborne sensor systems from staging locations and test support locations back to bed 

down locations.

60 October 2013
Airborne sensors could use the following bed down locations: Jones Riverside Airport, 

Tulsa, OK; Majors Army Air Field, Greenville, TX; Edwards AFB, CA; and Kirtland 

AFB, NM. Staging locations could be any number of airports and AFBs and test 

locations included airspace over Broad Ocean Area (BOA), airspace over land portions of 

ranges and airspace over ocean portion of ranges.

Land-based mobile sensors would be used up to 10 times per year at various locations. 

Activities associated with using land-based mobile sensors include transporting the sensor

to the test site, site preparation activities, and checking out sensors, disassembling the 

sensor and transporting the sensor back to the storage or bed down location.

Thirteen broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that no significant impacts would occur as a 

result of routine movements of test assets.

MDA has conducted numerous test activities using airborne and land-based mobile

sensors and no environmental impacts have been reported or observed.

Reference: Ground-Based Midcourse Defense Sea-Based X-Band Radar (SBX) 

Placement and Operation Environmental Assessment, October 2005, resulting in a 

FONSI

The EA analyzed the operation, permanent mooring and temporary anchoring of the SBX 

vessel at several locations in Alaska. 

Thirteen broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that no significant impacts would occur as a 

result of supporting, position/secure and operating the SBX.

No adverse environmental impacts have been observed due to the deployment and 

operation of the SBX since its initial deployment and operation.

Reference: RCE Integrated Flight Test #10, January 2002. Qualifies for Navy 

CATEX (f)(11).

The proposed action among other things was to use a Navy Ticonderoga Class Aegis 

Cruiser with sensors aboard to detect, track and collect data on the target during IFT-10. 

The Navy ship would perform routine operations and would conform to standard fleet 

operating procedures. Also, the airborne laser aircraft, a modified 747 aircraft, would use 

the IFT-10 missile as a target of opportunity. 

Reference: RCE Integrated Flight Test #9, August 2002. Qualifies for Navy CATEX 

(f) (11).

The proposed action among other things was to use a Navy Ticonderoga Class Aegis 

Cruiser with sensors aboard to detect, track and collect data on the target during IFT-9. 

61 October 2013
The Navy ship would perform routine operations and would conform to standard fleet 

operating procedures.

Reference: RCE Integrated Flight Tests #13A and #13B, August 2003. Qualifies for 

Navy CATEX (f) (11).

The proposed action among other things was to use a Navy AEGIS CG47 Class Aegis 

Cruiser with sensors aboard to detect, track and collect data on the launches. The Navy 

ship would perform routine operations and would conform to standard fleet operating 

procedures. Also, the airborne laser aircraft, a modified 747 aircraft, would use the IFT 

#13A and #13B missiles as targets of opportunity. 

Reference: RCE Integrated Flight Test-13C (IFT 13C), February 2004. Qualifies for 

Navy CATEX (f) (11).

The proposed action among other things was to use a Navy Ticonderoga Class Aegis 

Cruiser with sensors aboard to detect, track and collect data on the target during IFT-13C. 

The Navy ship would perform routine operations and would conform to standard fleet 

operating procedures. Also, the airborne laser aircraft, a modified 747 aircraft, would use

the IFT-13C missile as a target of opportunity. 

Reference: RCE Integrated Flight Test-14 (IFT-14), July 2004. Qualifies for Navy 

CATEX (f) (11).

The proposed action among other things was to use a Navy Ticonderoga Class Aegis 

Cruiser with sensors aboard to detect, track and collect data on the target during IFT-14. 

The Navy ship would perform routine operations and would conform to standard fleet 

operating procedures. Also, the airborne laser aircraft, a modified 747 aircraft, would use

the IFT-14 missile as a target of opportunity.

Reference: RCE Operation and Maintenance of the MV Pacific Collector (PC) and 

MV Pacific Tracker (PT) to Support MDA Requirements as Sea-Based Mobile Sensor 

Platforms, July 2009. Qualifies for Navy CATEX (f)(11).

The PC and PT are mobile sea-based platforms designed to host sensors. The proposed 

action is for Maritime Administration (MARAD), as MDA’s executing agent, to modify, 

operate, and maintain the PC and PT to host MDA sensors to track BMDS test 

interceptors and/or target missiles launched from any of the test ranges (Reagan Test Site, 

Kodiak Launch Complex, Vandenberg AFB, PMRF, Western Range, and Wake Island 

and land-based instrumentation sites) as well as the broad ocean area using either air- or 

sea-launch platforms. Both vessels would be homeported at the Cascade General 

Portland Shipyard, Portland, OR.

62 October 2013
Table B-11.1 Comparative Analysis of MDA CATEX B-11 to Other Agency CATEXs.

Benchmarking 

Categories

MDA U.S. Navy U.S. Air Force U.S. Coast Guard

Notes

Applicable 

CATEXs B-11 (f)(11) A2.3.31

COMMANDANT INSTRUCTION M16475.1D, 

Categorical Exclusions

Characteristics 

of the Action

Routine movement of mobile test assets (such as 

ships, aircraft, mobile sensors, telemetry, etc.) for 

routine missile defense test and evaluation, for 

repair/overhaul or maintenance, or for home port 

reassignments where no new support facilities are 

required.

Proposed action is limited to routine movement of 

mobile assets (such as ships and aircraft) for homeport 

reassignments, for repair/overhaul, or to train/perform 

as operational groups where no new support facilities 

are required.

MDA has extensive experience working at U.S. Navy 

installations such as PMRF, HI; Point Mugu Sea 

Range, CA; San Nicolas Island, CA; and Dahlgren 

Naval Base, VA.

Proposed action is limited to relocating a small number 

of aircraft to an installation with similar aircraft that 

does not result in a significant increase of total flying 

hours or the total number of aircraft operations, a 

change in flight tracks, or an increase in permanent 

personnel or logistics support requirements at the 

receiving installation. Repetitive use of this CATEX at 

an installation requires further analysis to determine 

there are not cumulative impacts. 

MDA has extensive experience working at U.S. Air 

Force Installations such as Vandenberg AFB, CA; 

Edwards AFB, CA; Wake Island; Clear AFS, AK; 

Elmendorf AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

Proposed action is limited to realignment or initial 

home porting of mobile assets, including vessels and 

aircraft, to existing operational facilities that have the 

capacity to accommodate such assets or where 

supporting infrastructure changes will be minor in 

nature to perform as new home ports or for repair and 

overhaul. Note: If the realignment or home porting 

would result in more than a one for one replacement 

of assets at an existing facility, then the checklist 

required for this CATEX must specifically address 

whether such an increase in assets could trigger the 

potential for significant impacts to protected species 

or habitats before use of the CATEX can be 

approved. 

Methods of 

Implementing 

the 

Action

Work with Military Services to find suitable locations 

for porting/basing/staging or repair/maintenance 

activities.

Work with host installation or commercial port/airport

to identify applicable laws, regulations, and SOPs.

Work with host installation or commercial port/airport

to either review existing and/or prepare necessary 

NEPA documentation.

Work with host installation or commercial airport/port 

to obtain any required support structures, equipment, 

or minor site preparation activities.

Deploy mobile assets to site and ensure repair and 

maintenance operations conform to facility operation 

and environmental management plans. 

Installation staff to find suitable locations for 

porting/basing or repair/maintenance activities.

Installation staff to identify applicable laws, 

regulations, and SOPs.

Installation staff either review existing and/or prepare 

necessary NEPA documentation.

Installation staff obtains any required support 

structures, equipment, or minor site preparation 

activities.

Deploy mobile assets to site and ensure repair and 

maintenance operations conform to facility operation 

and environmental management plans. 

Same Same

Frequency of the 

Actions

Movement of MDA assets occurs infrequently at any 

one site; however, they occur routinely at locations 

used by MDA.

Navy movement of sea-based assets and aircraft 

occurs much more frequently.

Air Force movement of aircraft, sensors and other 

assets occurs much more frequently.

Coast Guard movement of sea-based assets and 

aircraft occurs much more frequently.

Typical operations subject to conditions of host 

installation or commercial airport/port’s regulatory 

permits and master schedule.

Applicable 

Regulations

NEPA, CAA, RCRA, and applicable state regulations. Same Same Same

Applicable SOPs Installation/Manufacturer specific Same Same Same

Timing and 

Context

Movement of assets is conducted several days or 

weeks before test events and then returned to home 

port or base several days after the test event. Delivery 

of a new test asset or decommissioning of an existing 

test asset occurs very infrequently. 

Same for testing and missions, but more frequent. Same for testing and missions, but more frequent. Same for testing and missions, but more frequent.

Extraordinary 

Circumstances

None Same Same Same

63 October 2013
Benchmarking 

Categories

MDA U.S. Navy U.S. Air Force U.S. Coast Guard Notes

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no 

known significant impacts from movement of theses 

of assets.

Same Same Same

64 October 2013
Table B-11.2 Comparative Analysis of MDA CATEX B-11 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Mobile Launch Platform (MLP) Environmental Assessment, 

June 2004, FONSI Signed

Mobile Sensors Environmental Assessment, September 2005, 

FONSI Signed

Ground-Based Midcourse Defense Sea-Based X-Band Radar 

(SBX) Placement and Operation Environmental Assessment, 

October 2005, FONSI Signed

Applicable 

CATEXs B-11

Characteristics 

of the Action

Routine movement of mobile test assets (such as ships, aircraft, 

mobile sensors, telemetry, etc.) for routine missile defense test and 

evaluation, for repair/overhaul or maintenance, or for home port 

reassignments where no new support facilities are required.

The EA analyzed the use of the existing MLP to provide a mobile 

sea-based platform from which to test sensors (radars, telemetry, 

and optical systems), ballistic missile targets, and defensive missile 

interceptors in support of MDA’s mission. The MLP is the former 

USS Tripoli (LPH 10), a converted U.S. Navy Iwo Jima Class 

Amphibious Assault Ship (Helicopter). 

The MLP has no engines for propulsion and would be towed from 

port to the test event location. Either a government-owned 

contractor-operated or commercial tug would tow the MLP from its 

home port (Mare Island, CA) to specific locations for test events. 

Post-launch activities would include transporting the MLP from the 

test event location to the ordnance loading port or home port as 

appropriate.

This EA analyzed the use of land-based mobile sensors and airborne 

sensor systems (i.e., optical and infrared systems) to provide 

comprehensive and realistic test surveillance and tracking data 

capabilities in support of the MDA BMDS. 

The proposed airborne sensor systems would be housed in a 

modified Gulfstream IIB aircraft and a modified DC-10 aircraft. 

Activities associated with the airborne sensor systems included 

among other things flying the airborne sensor systems to test 

support locations; setting up, checking out and performing 

maintenance on aircraft; flying airborne sensor systems from 

staging locations and test support locations back to bed down 

locations.

Airborne sensors could use the following bed down locations: 

Jones Riverside Airport, Tulsa, OK; Majors Army Air Field, 

Greenville, TX; Edwards AFB, CA; and Kirtland AFB, NM. 

Staging locations could be any number of airports and AFBs and 

test locations included airspace over Broad Ocean Area (BOA), 

airspace over land portions of ranges and airspace over ocean 

portion of ranges.

Land-based mobile sensors would be used up to 10 times per year at 

various locations. Activities associated with using land-based 

mobile sensors include transporting the sensor to the test site, site 

preparation activities, and checking out sensors, disassembling the 

sensor and transporting the sensor back to the storage or bed down 

location.

The EA analyzed the operation, permanent mooring and temporary 

anchoring of the SBX vessel at several locations in Alaska.

Methods of 

Implementing 

the Action

Work with Military Services to find suitable locations for 

porting/basing or repair/maintenance activities.

Work with host installation or commercial port/airport to identify 

applicable laws, regulations, and SOPs.

Work with host installation or commercial port/airport to either 

review existing and/or prepare necessary NEPA documentation.

Work with host installation or commercial airport/port to obtain any 

required support structures, equipment, or minor site preparation 

activities.

Deploy mobile assets to site and ensure repair and maintenance 

operations conform to facility operation and environmental 

management plans. 

Same Same Same

Frequency of the 

Actions

Movement of MDA assets occurs infrequently at any one site; 

however, they occur continuously at locations used by MDA.

Up to four tests per year potentially requiring movement of assets. Four or more flights per year for tests and movement of assets. One time home porting and infrequent transit to broad ocean areas.

Applicable 

Regulations

NEPA, CAA, RCRA, and applicable State Regulations. Same Same Same

Applicable SOPs Installation/Manufacturer specific Same Same Same

65 October 2013
Benchmarking 

Categories MDA Mobile Launch Platform (MLP) Environmental Assessment, 

June 2004, FONSI Signed

Mobile Sensors Environmental Assessment, September 2005, 

FONSI Signed

Ground-Based Midcourse Defense Sea-Based X-Band Radar 

(SBX) Placement and Operation Environmental Assessment, 

October 2005, FONSI Signed

Applicable 

CATEXs B-11

Timing and 

Context

Movement of assets is conducted several days or weeks before test 

events and then returned to home port or base several days after the 

test event. Delivery of a new test asset or decommissioning of an 

existing test asset occurs very infrequently. 

Same Same Same 

Extraordinary 

Circumstances

None. Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known significant 

impacts from movement of these kinds of assets.

The MLP has been used two to five missions per year since 2005 

and no significant environmental impacts have been observed.

MDA has conducted numerous test activities using airborne sensors 

and no environmental impacts have been reported or observed.

No adverse environmental impacts have been observed due to the 

deployment of the SBX.

66 October 2013
B-12. Activities and operations to be conducted in an existing non-historic structure which 

are within the scope of and are compatible with the present functional use of the 

building, will not result in a substantial increase in waste discharged to the 

environment, will not result in substantially different waste discharges from current or 

previous activities, and emissions will remain within established permit limits, if any. 

Activities contemplated by this CATEX are those undertaken within structures in a manner 

compliant with established Federal, state, local, and DoD requirements to protect public safety 

and the quality of the human environment. Examples of structures contemplated include office 

buildings, data centers, warehouses, launch facilities, telemetry/radar sites, etc. The Team found 

that such actions are performed in structures by MDA on many Host installations or ranges, or 

commercial sites without any harm to the quality of the human environment. Because MDA 

does not own real property, it typically uses existing structures at Host installations, ranges, or 

commercial developments, some of which may also require minor modifications (major 

renovation and construction of new facilities are activities not contemplated in this CATEX). 

MDA actions are no different in character and scope than those conducted by the Military 

Services on the same installations. The methods of implementing the actions and the 

requirements governing them are also the same on host installations and at commercial sites 

because MDA must comply with the host installation’s environmental and cultural resources

management programs in addition to Federal, state, and local requirements. The frequency and 

timing of these activities also does not differ significantly from the Host installation’s actions.

Wastes and air emissions from MDA activities on Host installations or commercial sites are 

subject to the same controls as the Host installation’s activities and Federal, state and local 

regulations and requirements. Demolition of structures is not covered by this CATEX. 

Adverse environmental impacts would not occur because:

1) The structure would not be historic;

2) The proposed activities would be consistent with the activities of previously and/or currently 

conducted at that location;

3) No change in the type of wastes and emissions generated would occur; and

4) No significant increase in the quantity of wastes and emissions under this CATEX would be 

allowed.

The Team specifically limited this CATEX to actions conducted in an existing structure 

compatible with and similar in scope to the ongoing functional uses of those structures and 

consistent with previously established safety levels and in compliance with Federal, state, tribal, 

and local requirements to protect the environment. This was done to ensure there would be no 

potential for significant environmental impacts contemplated by the application of this CATEX. 

In addition, this CATEX is supported by environmental reviews and administrative records from 

MDA projects.

As documented in Table B-12.1 and B-12.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

67 October 2013
CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent; and 

5) No known significant impacts are associated with this proposed activity. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record 

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(b)(4) Proposed activities and operations to be conducted in an existing non-historic 

structure which are within the scope and compatibility of the present functional use of the 

building, will not result in a substantial increase in waste discharged to the environment, 

will not result in substantially different waste discharges from current or previous 

activities, and emissions will remain within established permit limits, if any (REC 

required).

Federal Emergency Management Agency

Reference: 44 CFR 10.8 (d) (2)

(xvii) Actions conducted within enclosed facilities where all airborne emissions, 

waterborne effluent, external radiation levels, outdoor noise, and solid and bulk waste 

disposal practices comply with existing Federal, state, and local laws and regulations. 

Missile Defense Agency Environmental Reviews

Reference: Ground-Based Midcourse Defense (GMD) Initial Defensive Operations 

Capability (IDOC) at Vandenberg Air Force Base Environmental Assessment, August 

2003, resulting in a FONSI

The EA analyzed the environmental impacts resulting from the use and/or modification 

of four existing missile silos and other support facilities at Vandenberg AFB as part of 

the GMD IDOC. 

68 October 2013
Existing facilities would be required for the following functions: Missile

Assembly/EKV/Interceptor Integration, Security Response Force Outpost, Readiness 

Station, GMD Fire Control/Communication components (IDT, GMD Communication 

Node, and GMD Fire Control), interceptor storage, administrative/office space, Peculiar 

Support Equipment (IDOC-associated equipment such as the “strongback” trailer used 

for transport) storage, EKV fuel tank storage, EKV oxidizer tank storage, and 

warehouse/maintenance/storage facilities. Several of these facilities would require 

interior modifications and the installation of additional infrastructure (i.e., security 

fencing, lighting, communications lines, water line upgrades, re-grading for proper storm

drainage, septic tank and leach field, etc.). 

Thirteen broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that no significant impacts would occur from

implementing the proposed activities for the IDOC at Vandenberg AFB as long as the 

noted mitigation actions were implemented. No adverse environmental effects were 

reported or observed from launch facility reactivation and support facility modifications.

Reference: New Mission Beddown and Construction, Clear Air Force Station (AFS),

Alaska Environmental Assessment, August 2012, resulting in a FONSI

The purpose of the proposed action was to upgrade the Clear AFS Early Warning Radar 

(EWR) to add capabilities for search, acquisition, object classification and tracking. 

Computer system upgrades and internal facility modifications would occur inside the 

Radar Facility to accommodate new equipment. 

The environmental analysis shows that no significant impacts would occur from the 

system upgrade and facility modification activities associated with the Proposed Action. 

Construction is planned for 2013.

Reference: REC Booster Vehicle (BV) Assembly Operations at Lockheed Martin 

Facilities, Courtland, AL, July 2002. Qualifies for Army CATEX (b)(4).

The proposed action was to assemble and test booster stages of the GBI missile at 

Lockheed Martin Space Systems Company facilities in Courtland, AL. These activities 

were in the scope and compatibility of the present functional use of the building with no 

substantial increases in waste discharges.

Reference: REC Kinetic Energy Interceptor Program – Stage-2 Rocket Motor 

Manufacture and Static Fire Tests at the Alliant Techsystems, Inc. (ATK) Elkton 

Facility, Maryland, November 2006. Qualifies for Army CATEX (B)(4).

ATK would manufacture and static fire test up to four Kinetic Energy Interceptor (KEI)

Stage-2 rocket motors at its existing contractor facilities in Maryland. The ATK-Elkton 

facility has been manufacturing and testing solid rocket motors since 1948.

69 October 2013
Reference: REC Kinetic Energy Interceptor Program – Stage-1 Rocket Motor 

Manufacture and Static Fire Tests at Alliant Tech Launch Systems (ATK) Clearfield 

Facility, Utah, July 2006. Qualifies for Army CATEX (b)(4) and Navy.

ATK would manufacture and static fire test up to five KEI Stage-1 rocket motors at its 

existing contractor facilities in Utah. The Bacchus Facility has been manufacturing solid 

rocket motors since 1958 for various DoD and commercial programs.

Reference: REC Radiation Testing of Microsatellite Components, May 2007. 

Qualifies for Army CATEX (b)(4).

Proton testing of commercial-off-the-shelf (COTS) microsatellite components used by 

MDA's Distributed Sensing Experiment (DSE) program would be conducted at the 

Indiana University Cyclotron Facility in Bloomington, Indiana to evaluate the 

performance of COTS components under a space radiation environment. During testing, 

each component will be irradiated with 200 Mega Electron Volt (MeV) protons and 

monitored to identify the sensitivity of microsatellite components to radiation at levels 

that simulate the environment in space. A total of four tests are planned.

70 October 2013
Table B-12.1 Comparative Analysis of MDA CATEX B-12 to Other Agency CATEXs

Benchmarking 

Categories MDA U.S. Army Federal Emergency Management Agency

Notes

Applicable 

CATEXs B-12 (b)(4) 44 CFR 10.8 (d) (2)

Characteristics of 

the Action

Activities and operations to be conducted in an existing nonhistoric structure which are within the scope of and are compatible 

with the present functional use of the building, will not result in a 

substantial increase in waste discharged to the environment, will 

not result in substantially different waste discharges from current 

or previous activities. Does not include major renovations or new 

construction.

Proposed action is limited to operations conducted in an existing 

non-historic structure which are within the scope and compatibility 

of the present functional use of the building, will not result in a 

substantial increase in waste discharged to the environment, will 

not result in substantially different waste discharges from current 

or previous activities, and emissions will remain within 

established permit limits, if any (REC required).

MDA has extensive experience working at U.S. Army installations 

such as the Ronald Reagan Test Site, USAKA; WSMR, NM; 

Redstone Arsenal, AL; Fort Greely, AK; Fort Drum, NY; and Fort 

Belvoir, VA.

Proposed action is limited to actions conducted within enclosed 

facilities where all airborne emissions, waterborne effluent, 

external radiation levels, outdoor noise, and solid and bulk waste 

disposal practices comply with existing Federal, state, and local 

laws and regulations. 

Methods of 

Implementing the 

Action

Work with host installation or property owner to identify 

applicable laws, regulations, management plans and SOPs.

Work with host installation or property owner to obtain required

permits and to record and report resource and material usage and 

disposal.

Work with host installation or property owner to either review 

existing documentation and/or prepare necessary NEPA

documentation.

Work with host installation property owner to conduct any 

required coordination with Federal and state agencies.

Installation staff to identify applicable laws, regulations, 

management plans, SOPs.

Installation staff to obtain required permits and record and report 

resource and material usage and disposal.

Installation staff to either review existing documentation and/or 

prepare necessary NEPA documentation.

Conduct any required coordination with Federal and state 

agencies.

Similar All these activities are conducted according to detailed regulations 

that are fundamentally consistent across Federal agencies.

Differences in state regulations could occur.

Frequency of the 

Actions

Relatively infrequent compared to Military Service actions at 

locations used by MDA; MDA’s small footprint occasionally 

changes to accommodate new research development, test 

programs or operational requirements as the BMDS continues to 

spirally evolve.

Greater Greater Typical range operations subject to conditions of installation’s 

regulatory permits and management plans.

Applicable 

Regulations

NEPA, CERCLA, RCRA, CWA, CAA, and other applicable 

Federal and state regulations, DoD and Military Service 

requirements, local ordinances, and industry standards.

Same Same

Applicable SOPs Installation specific, but most are consistent among installations, 

because of proscriptive nature of Federal and state regulations.

Same Same

Timing and 

Context

Leasing/use of new space occurs infrequently and is tied to the 

research, development, testing of a new system/program or 

operational requirements. MDA use, transport, and disposal 

activities correspond to the infrequent change in MDA’s foot print 

and/or MDA’s test activities.

Continuous over time at high levels relative to MDA. Continuous over time at high levels relative to MDA.

Extraordinary 

Circumstances

None Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known significant 

impacts from these types of operations. 

Same Same

71 October 2013
Table B-12.2 Comparative Analysis of MDA CATEX B-12 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Ground-Based Midcourse Defense (GMD) Initial Defensive Operations Capability (IDOC) at Vandenberg Air Force Base 

Environmental Assessment, August 2003, FONSI Signed

New Mission Beddown and Construction, Clear Air Force 

Station (AFS), Alaska Environmental Assessment, August,

2012, FONSI Signed Applicable 

CATEXs B-12

Characteristics of 

the Action

Activities and operations to be conducted in an existing non-historic structure which are 

within the scope of and are compatible with the present functional use of the building, 

will not result in a substantial increase in waste discharged to the environment, will not 

result in substantially different waste discharges from current or previous activities. 

Does not include major renovations or new construction.

The Proposed Action would use and/or modify four existing missile silos 

and other supporting facilities at Vandenberg AFB as part of the GMD 

IDOC. 

The purpose of the proposed action was to upgrade the Clear AFS EWR 

to add capabilities for search, acquisition, object classification and 

tracking. The proposed action among other things is to upgrade the EWR, 

GFC/C and GMD SSF Equipment within or adjacent to the Radar 

Facility. Equipment would be installed in the Radar Facility and on the 

roof. Internal facility modifications would occur inside the Radar Facility 

to accommodate new equipment. 

Methods of 

Implementing the 

Action

Work with host installation or property owner to identify applicable laws, regulations, 

management plans and SOPs.

Work with host installation or property owner to obtain required permits and to record 

and report resource and material usage and disposal.

Work with host installation or property owner to either review existing documentation 

and/or prepare necessary NEPA documentation.

Work with host installation property owner to conduct any required coordination with 

Federal and state agencies.

Same Same

Frequency of the 

Actions

Relatively infrequent compared to Military Service actions at locations used by MDA; 

MDA’s small footprint occasionally changes to accommodate new research 

development, test programs or operational requirements as the BMDS continues to 

spirally evolve.

One time – completed One time

Applicable 

Regulations

NEPA, CERCLA, RCRA, CWA, CAA, and other applicable Federal and state 

regulations, DoD and Military Service requirements, local ordinances, and industry 

standards.

Same Same

Applicable SOPs Installation specific, but most are consistent among installations, because of 

proscriptive nature of Federal and state regulations.

Same Same

Timing and 

Context

Leasing/use of new space occurs infrequently and is tied to the research, development, 

testing of a new system/program or operational requirements. MDA use, transport, and 

disposal activities correspond to the infrequent change in MDA’s foot print and/or 

MDA’s test activities.

Same Same

Extraordinary 

Circumstances

None Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known significant impacts from these 

types of operations. 

No adverse environmental effects have been observed from silo reactivation 

and supporting facility modification since project construction.

Facility modifications have not begun.

72 October 2013
B-13. Acquisition, installation, modification, routine repair and replacement, and 

operation of utility (e.g., water, sewer, and electrical) and communication systems, 

mobile antennas, data processing cable, and similar electronic equipment that use 

existing rights-of-way, easements, distribution systems, facilities, or previously 

disturbed land. (REC required).

Activities contemplated by this CATEX are those undertaken within or near existing structures 

and facilities or along roads with existing rights-of ways or easements in a manner compliant 

with established Federal, state, local, and DoD requirements to protect public safety and the 

quality of the human environment. The Team limited the scope of the activities contemplated by 

this CATEX to using existing rights-of-way, easements, utility distribution systems, facilities

and/or previously disturbed land. These existing rights-of-way, easements, utility distribution 

systems, and facilities would include properties having already been disturbed by prior 

installation of utility and communications systems. Due to this prior disturbance, there would be 

little potential for significant environmental impact from the use of these properties. The Team 

realized that minor trenching for utilities could be required, but believed, based on our 

experience at host installations and test ranges, trenching (<3 feet deep) would be limited to 

existing easements and previously disturbed areas. By confining trenching to previously 

disturbed areas, existing easements and shallow depths, we are minimizing the potential impact 

to sensitive environments, cultural/historical/biological resources (i.e., less likely to run into a 

cultural, historical or biological resource if the area was either in an existing easement or already 

disturbed and the depth of the trenching was <3 feet).

The Team recognized this CATEX could involve actions with one or more extraordinary 

circumstances (i.e., would adversely affect public health or safety; threatens a violation of 

Federal, state or local environmental laws applicable to MDA; or involves a site that includes 

wetlands not covered by a nation-wide or regional permit, endangered or threatened species, 

historical or archeological resources or hazardous wastes, etc.). Therefore, to ensure only those 

actions having negligible impacts on the human environment are contemplated, the Team

proposed a REC be prepared to document no extraordinary circumstances exist and all CATEXscreening criteria are met or whether further NEPA analysis is required.

As documented in Table B-13.1 and B-13.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

73 October 2013
4) Extraordinary circumstances associated with its application absent and documented by a 

REC; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(e)(2) Acquisition, installation, and operation of utility and communication systems, 

mobile antennas, data processing cable and similar electronic equipment that use existing 

right-of-way, easement, distribution systems, and/or facilities (REC required).

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(36) Acquisition, installation, and operation of utility (e.g., water, sewer, electrical) and 

communication systems (e.g., data processing cable and similar electronic equipment) 

which use existing rights of way, easements, distribution systems, and/or facilities.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.12. Installing, operating, modifying, and routinely repairing and replacing utility 

and communications systems, data processing cable, and similar electronic equipment 

that use existing rights of way, easements, distribution systems, or facilities.

Federal Emergency Management Agency

Reference: 44 CFR10.8 (d) (2)

(ix) Acquisition, installation, or operation of utility and communication systems that use 

existing distribution systems or facilities, or currently used infrastructure rights-of-way.

Department of Energy

Reference: 10 CFR1021, Subpart D. Appendix B

B1.7 Acquisition, installation, operation, and removal of communication systems, data 

processing equipment, and similar electronic equipment. 

74 October 2013
B1.19 Siting, construction, and operation of microwave and radio communication towers 

and associated facilities, if the towers and associated facilities would not be in an area of 

great visual value.

B4.7 Adding fiber optic cable to transmission structures or burying fiber optic cable in 

existing transmission line rights-of-way.

Missile Defense Agency Environmental Reviews

Reference: National Missile Defense (NMD) Deployment Environmental Impact 

Statement, July 2000

This EIS analyzed among other things, the installation of a communication line between 

NMD elements. A fiber optic cable line may be required for potential deployment in 

Alaska and North Dakota. In Alaska, the land portion of fiber optic cable would be laid 

in Interior Alaska to connect potential NMD elements in central Alaska. In North 

Dakota, the cable would be laid in the ground. To the extent possible, the fiber optic

cable line route would follow existing road, utility, or rail corridors. The laying of fiber 

optic cable for the NMD program would be performed by a commercial fiber optic cable 

installation company per regional guidelines.

Fifteen broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that no significant impacts would occur from

implementing the proposed activities. No adverse environmental effects have been 

observed from installing any utility work.

Reference: Ground-Based Midcourse Defense (GMD) Validation of Operational 

Concept (VOC) Environmental Assessment, March 2002, resulting in a FONSI

For the GMD VOC test site components for GBI, the Fiber Optic Cable (FOC) network 

would provide the communications link between the components and sub-components of 

the GMD test sites. Existing FOC would be used whenever feasible. Where new FOC

was required, cable may be installed on either side of rights-of-way (normally roads or 

railroad tracks). The FOC would be buried to a depth of approximately 3 feet. To the 

extent possible, candidate cable routes were identified along existing rights-of-way,

minimizing the impact on the environment.

The EA determined the implementation of the proposed action would not result in

significant impacts to any of the resource areas analyzed.

Additional activities were determined necessary for Eareckson AFS and Beale AFB in 

December 2002. For Eareckson AFS these actions included among other things minor 

realignments of the FOC routes along existing rights-of-way and previously disturbed 

areas, and installation of a cable run between buildings. No new environmental impacts

were identified with these activities and no additional analysis was required in the 

existing EA.

75 October 2013
At Beale AFB, trenching and installation of FOC would occur from the base boundary

for approximately 2.3 miles. This new segment would connect to an existing fiber optic 

conduit on base. The FOC would be installed in the existing right-of-way along the east

shoulder of the road. There were no new environmental impacts identified with these 

activities and no new environmental analyses were found to be necessary. Therefore, the 

activities were determined to be categorically excluded by the USAF through their 

environmental impact analysis process. 

Off-base of Beale AFB, additional trenching and installation of FOC would occur from 

an existing communication line along Ostrum Road to Beale AFB, approximately 4.2 

miles. This cable would be installed in the right-of-way along the road shoulder and 

connect to the cable previously mentioned on South Beale Road. No new environmental 

impacts were identified with these activities and no additional analysis was required in 

this EA.

No adverse environmental effects were reported or observed from installation of the 

utility and communications lines. 

Reference: Ground-Based Midcourse Defense (GMD) Extended Test Range (ETR) 

Environmental Impact Statement, July 2003

Portions of the proposed actions included: Three fiber optic administrative telephone 

circuits for voice communications and alarm monitoring. Power and FOC would be 

routed in existing right of ways where practicable.

For communication among the components on the same installation, the ETR would 

maximize use of available communications assets, including cable. If communication 

cable is not available, new cable would be installed. Installation of new cable would be 

in existing conduit, if available. If not, new conduit would be constructed along rightsof-way. New conduit would be buried at a depth of approximately 3 feet, where 

necessary. 

No significant environmental impacts or cumulative impacts on resource areas addressed

for any activity considered in implementing the proposed action were found in this 

analysis. As appropriate, mitigation measures would be developed to address any sitespecific significant impacts. No environmental impacts were observed during 

construction and installation of fiber optics of the GMD Communications Network.

Reference: Ground-Based Midcourse Defense (GMD) Initial Defensive Operations 

Capability (IDOC) at Vandenberg Air Force Base Environmental Assessment, August 

2003, resulting in a FONSI

The proposed action, among other things, is for communication cable(s) to be installed 

between support facilities and silos, as required. Cables would be installed in existing 

conduits, where available. If existing conduits are not available, the cable(s) would be 

installed in new conduits that would be placed in previously disturbed areas of soil 

76 October 2013
(usually along the shoulders of existing roads) approved by the Vandenberg AFB 

Environmental Management Office where possible to avoid sensitive biological and 

cultural areas. Also, the new communications cable/conduit would be buried parallel to 

existing buried utility lines if cross country routes are required. Trenching for the new 

communications cable/conduit would have a maximum depth of 3 feet. If new cable 

conduit is necessary and must be placed near known archaeological sites, the conduit 

would be routed under the site deposits using a directional drilling rig. In this case, the 

conduit would be emplaced deep enough to avoid negative impacts to the site. 

Thirteen broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that no significant impacts would occur from

implementing the proposed activities for the IDOC at Vandenberg AFB. No adverse 

environmental effects have been observed from installing any utility work.

Reference: Relocatable In-flight Interceptor Communications System Data Terminal 

#2 at Vandenberg Air Force Base Supplemental Environmental Assessment (SEA), 

November 2007, resulting in a FONSI

The EA analyzed the installation of a Relocatable Integrated Data Terminal (RIDT) and 

communications equipment, within shelters, on concrete pads; backup power generator 

and uninterruptable power supply; communications hut; storage facility for spares; an 

above ground water tank for fire suppression, with on-site distribution system; and 

installation of a septic system for the existing ISFAC.

Communications lines would be extended from an existing power line along El Rancho 

Road, including a cross connection with the existing RIDT. The lines would be placed in 

a buried flexible conduit, to be installed via trenching. Commercial power would be

brought to the second RIDT from an existing power line along the east side of El Rancho 

Road. The new line would be installed by a combination of boring and trenching. A new 

water line with pump station would be required to provide water sufficient for fire 

fighting. Trenching for the water line would be required and buried power lines would be 

extended to the new pump station from the second RIDT site.

Based on analysis of the proposed construction and operation of a second RIDT at

Vandenberg AFB, this SEA identified no significant impacts affecting the quality of the 

human environment. No environmental impacts have been observed as a result of 

MDA’s construction and operation of the IDT #2 and supporting facilities at VAFB.

Reference: AF 813 GMD Validation of Operational Concept Testing Fiber Optic 

Cable (FOC) Installation at Beale AFB, February 2003. Qualifies for Air Force 

CATEX A2.3.12.

The proposed action was to provide FOC connection from the Upgraded Early Warning 

Radar to north and south off-base spurs connecting Beale AFB’s FOC network to a 

commercial FOC backbone through CA. On-base fiber connectivity would be a 

77 October 2013
combination of existing base fiber, new fiber installed in new conduit (trenching or 

boring required).

Reference: REC C2BMC Site Activation, April, 2004. Qualifies for Air Force 

CATEX A2.3.12.

The Command, Control, Battle Management and Communications (C2BMC) suite will 

be deployed in facilities that provide the infrastructure and communications interfaces to 

other BMDS elements and external systems. The suite consists of operator stations, 

mission servers, network management equipment, and security and external connection 

equipment. All equipment would be located within existing facilities that provide 

communications connectivity, power, shelter, security, and other services.

Reference: REC Replacement of Communications Cable at Fort Greely, Alaska, May 

2004. Qualifies for Army CATEX (e)2.

The proposed action was to replace a portion of communications cable. Trenching would 

be conducted within the existing right-of-way/easement of the existing communications 

cable.

Reference: REC GMD Entry Control Facility Relocations at Fort Greely, AK, 

February 2005. Qualifies for Army CATEX (e)(2).

The proposed action among other things was to installation of a well and a wastewater 

(septic) system; and installation of communication cables and utilities.

Reference: RCE MDA – 510, Telemetry Building at the Pacific Missile Range Facility 

(PMRF), Makaha Ridge, Kauai, HI, April 2005. Qualifies for Navy CATEX (36).

The proposed action included construction of a standalone pre-engineered building at 

PMRF and providing water, sewer, communications and electrical utilities by utility 

infrastructure already present at the site. Asphalt removal and trenching along developed 

areas of the site would be required for the utility connections.

Reference: AF813 Removal of Utilities and Walls between Bays 1, 2, and 3 in 

Building 151 at Edwards AFB, October 2005. Qualifies for Air Force CATEX 

A2.3.12.

The proposed action was to remove utilities and wall between bays 1, 2, and 3 to allow 

the Air Borne Laser program to proceed with future activities at this facility without 

unnecessary restrictions.

78 October 2013
Reference: AF 813 Re-Establish Leach Field at Bldg #1768, CES W/O # 38026, July 

2006. Qualifies for Air Force CATEX A2.3.12.

The proposed action was to replace the existing septic tank and leach field. Existing tank 

and leach field would be abandoned in place per Santa Barbara County requirements. A 

new tank and leach field would be installed in an area that would cause the lease impact 

on sensitive plant life in the area.

Reference: AF 813 MDA/GMD Operations at Vandenberg AFB, California – LF-24 

(Bldg 1965) New Communication Lines Connection, October 2006. Qualifies for Air 

Force CATEX A2.3.12.

The proposed action consisted of installation of a new buried communication line conduit 

at LF-24.

Reference: REC AN/TPY-2 Radar Deployment at the Ted Stevens Marine Research 

Institute (TSMRI) on the National Oceanic and Atmospheric Administration (NOAA) 

Site in Juneau, Alaska in Support of Flight Test Ground-Based Interceptor (FTG)-04, 

May 2007. Qualifies for Army CATEX (E)(2).

The proposed action was the temporary deployment of the AN/TPY-2 Radar at the 

TSMRI in Juneau, AK. Actions included siting, transport, set up, calibration and 

operation of the Radar. Among other things considered was the installation of temporary 

lighting, installation of grounding and lightning protection poles approximately 25 feet 

tall and installation of two 6 foot satellite dishes for communications. 

Reference: AF 813 MDA - Modification of Bldg 988 for Administration Space, March 

2009. Qualifies for Air Force CATEX A2.3.12.

The proposed action included among other things: 1) install new fire alarm system and 

repair existing fire suppression system, 2) repair existing heating, ventilations and air 

conditioning (HVAC) system, remove existing boiler, and construct new concrete 

equipment pads, 3) replace existing transformer and repair existing electrical panels, 3) 

install new communication lines and repair/upgrade communication panels, and 4) 

replace/upgrade of the septic tank and leach field.

Reference: AF 813 MDA – Satellite Communications Fiber Optic Cable Installation 

(SATCOM FOC), July 2010. Qualifies for Air Force CATEX A2.3.12.

New FOC would be installed near the intersection of Washington Avenue and Airfield 

Road using existing conduit/ducts and handholes where possible. Installation of new 

underground conduits and handholes in several places will be needed via trenching and 

excavation. The majority of work would be 6 to 10 feet off the paved roadway.

79 October 2013
Reference: AF 813 Beddown of Missile Defense Agency (MDA) Mobile Telemetry 

system at Kaena Point Satellite Tracking Station, December, 2010. Qualifies for Air 

Force CATEX A2.3.12.

The proposed action was to temporary operate a transportable telemetry antenna system 

in Hawaii. Among other things considered was providing fiber for transmission of up to 

four steams of unclassified telemetry data between HULA A and HULA B; connection to 

site power; installation of air-conditioning equipment; and installation of commercial 

long distance phone lines.

Reference: AF 813 Air-borne Infrared Ground-based Operations at Site 460, VAFB, 

June 2011. Qualifies for Air Force CATEX A2.3.12.

MDA would set up and test an Air-Borne Infrared Radar (ABIR) Data Collection system 

at VAFB Site 460. The system consists of: 1) Multispectral Targeting System-B groundmounted sensor, 2) an airborne-capable computer processor enclosed in a secure shelter, 

and 3) an Operations Control Van to support personnel monitoring the data and 

equipment.

Reference: AF 813 VAFB Re-Route Power Lines to Underground at Launch 

Facilities (LF-02, LF-03, LF-21, LF-23), October 2011. Qualifies for Air Force 

CATEX A2.3.12.

The proposed action was to move overhead power lines at LF-02, -03, -21, and -23 to 

underground beginning at the first available pole from the outer perimeter fence. Two 

methods for installing the new underground primary conduit and wire were proposed: 

trenching with concrete encasement and directional boring.

80 October 2013
Table B-13.1 Comparative Analysis of MDA CATEX B-13 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force

Federal Emergency Management 

Agency

Notes

Applicable 

CATEXs B-13 (e)(2) (f)(36) A2.3.12 44 CFR 10.8 (d) (2)

Characteristics 

of the Action

Acquisition, installation, modification, 

routine repair and replacement, and 

operation of utility (e.g. water, sewer, 

electrical) and communication systems, 

mobile antennas, data processing cable and 

similar electronic equipment that use 

existing rights-of-way, easements, 

distribution systems, facilities, or previously 

disturbed land. (REC is required). 

Utility and communications equipment, 

wiring and pipes are placed on existing 

rights-of-way, easements, distribution 

system facilities, or previously 

disturbed/used area (dirt, gravel, or 

concrete/asphalt roads or pads).

Limited site preparations (e.g., grading, 

filling, trenching, etc.), if any, are conducted; 

spill containment barriers are used to contain 

fuel spills and coolant leaks during 

construction activities or test events.

Cables can either lie on ground or be in 

conduit; if site conditions and time permits, 

cabling can be placed in shallow trenches 

dug in previously disturbed areas and utility 

easements.

Acquisition, installation, and operation of 

utility and communication systems, mobile 

antennas, data processing cable and similar 

electronic equipment that use existing rightof-way, easement, distribution systems, 

and/or facilities (REC required).

MDA has extensive experience working at 

U.S. Army installations such as the Ronald 

Reagan Test Site, USAKA; WSMR, NM; 

Redstone Arsenal, AL; Fort Greely, AK; 

Fort Drum, NY; and Fort Belvoir, VA.

Acquisition, installation, and operation of 

utility (e.g., water, sewer, electrical) and 

communication systems (e.g., data 

processing cable and similar electronic 

equipment) which use existing rights of way, 

easements, distribution systems, and/or 

facilities.

MDA has extensive experience working at 

U.S. Navy installations such as PMRF, HI; 

Point Mugu Sea Range, CA; San Nicolas 

Island, CA; and Dahlgren Naval Base, VA.

Installing, operating, modifying, and 

routinely repairing and replacing utility and 

communications systems, data processing 

cable, and similar electronic equipment that 

use existing rights of way, easements, 

distribution systems, or facilities.

MDA has extensive experience working at 

U.S. Air Force Installations such as 

Vandenberg AFB, CA; Edwards AFB, CA; 

Wake Island; Clear AFS, AK; Elmendorf 

AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

(ix) Acquisition, installation, or operation of 

utility and communication systems that use 

existing distribution systems or facilities, or 

currently used infrastructure rights-of-way.

Limiting proposed action to areas that are 

previously disturbed minimizes the potential 

to disturb sensitive environmental and/or 

cultural resources. 

Relying on limited site preparation 

minimizes potential impacts from 

construction activities.

Use of spill containment barriers prevents 

contamination of soil.

Limiting trenching to shallow depths in 

established easements minimizes the 

potential to disturb sensitive environments 

and cultural resources.

Applying permit operating conditions and 

local requirements minimizes potential air 

impacts.

Methods of 

Implementing 

the Action

Work with host installation or property 

owner to find suitable location and 

permission to install and operate utilities, 

equipment, or mobile antennas.

Work with host installation or property 

owner to identify applicable laws, 

regulations, SOPs, and existing areas with 

known natural and/or cultural resources 

and/or areas of environmental contamination 

to avoid.

Work with host installation or property 

owner to either review existing 

documentation and/or prepare necessary 

NEPA documentation.

Work with host installation or property 

owner to conduct any required site 

preparation activities and/or coordination 

with Federal and state agencies.

Installation staff to find suitable location to 

install and operate utilities or equipment. 

Installation staff to identify applicable laws, 

regulations, management plans, SOPs, and 

existing areas with known natural and/or 

cultural resources and/or areas of 

environmental contamination to avoid.

Installation staff to either review existing 

documentation and/or prepare necessary 

NEPA documentation.

Conduct any required site preparation and/or 

coordination with Federal and state agencies.

Same Same Similar Construction and repair of utility systems on 

host installation and test ranges or 

commercial sites is a usual and customary 

activity, which conforms to the 

installation/range’s master plan and all 

appropriate Federal and state regulations.

81 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force

Federal Emergency Management 

Agency Notes

Frequency of the 

Actions

Occasional. Same Same Same Same Typical operations subject to conditions of 

installation or commercial site’s regulatory 

permits and master schedule.

Applicable 

Regulations

NEPA, CWA, CAA, biological and cultural 

resource protection regulations, and other 

applicable state regulations.

Same, plus UES. Same Same Same

Applicable SOPs Installation/Manufacturer specific Same Same Same Same

Timing and 

Context

Could occur any time of the year. MDA 

relies on installation’s or commercial site’s 

infrastructure. 

Sam Same Same Same

Extraordinary 

Circumstances

Presence of cultural/historic resources 

threatened or endangered species, or 

environmental contamination.

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of 

no known significant impacts from these 

operations. 

Same Same Same Unknown (but expected to be similar)

82 October 2013
Table B-13.2 Comparative Analysis of MDA CATEX B-13 to MDA Environmental Analyses.

Benchmarking 

Categories MDA National Missile Defense Deployment 

Environmental Impact Statement 

July 2000

Ground-Based Midcourse Defense 

(GMD) Validation of Operational 

Concept (VOC) Environmental 

Assessment, March 2002, FONSI 

Signed

Ground-Based Midcourse Defense 

(GMD) Extended Test Range (ETR) 

Environmental Impact Statement, 

July 2003

Initial Defensive Operations 

Capability (IDOC) at Vandenberg 

Air Force Base Environmental 

Assessment, August 2003, FONSI 

Signed

Relocatable In-Flight Interceptor 

Communications System Data 

Terminal (IDT) #2 at Vandenberg Air 

Force Base, Supplemental 

Environmental Assessment, 

November 2007, FONSI Signed

Applicable 

CATEXs B-13

Characteristics 

of the Action

Acquisition, installation, modification, routine repair and 

replacement, and operation of utility (e.g. water, sewer, 

electrical) and communication systems, mobile antennas, 

data processing cable and similar electronic equipment 

that use existing rights-of-way, easements, distribution 

systems, facilities, or previously disturbed land. (REC is 

required). 

Utility and communications equipment, wiring and pipes 

are placed on existing rights-of-way, easements, 

distribution system facilities, or previously disturbed/used 

area (dirt, gravel, or concrete/asphalt roads or pads).

Limited site preparations (e.g., grading, filling, trenching, 

etc.), if any, are conducted; spill containment barriers are 

used to contain fuel spills and antifreeze leaks during 

construction activities or test events.

Cables can either lie on ground or be in conduit; if site 

conditions and time permits, cabling can be placed in 

shallow trenches dug in previously disturbed areas and 

utility easements.

Among other activities, the EIS 

analyzed the installation of utility and 

power cables, and water and sewer lines 

at various potential deployment 

locations. 

An FOC network would be provided as

the communications link between the 

components and sub-components of the 

GMD test sites. Existing FOC would be 

used whenever feasible. Where new 

FOC was required, cable may be 

installed on either side of rights-of-way 

(normally roads or railroad tracks). The 

FOC would be buried to a depth of 

approximately 3 feet. To the extent 

possible, candidate cable routes were 

identified along existing rights-of-way, 

minimizing the impact on the 

environment.

Portions of the Proposed Actions 

included: Three fiber optic 

administrative telephone circuits for 

voice communications and alarm 

monitoring. Power and fiber optic cable 

would be routed in existing right of 

ways where practicable.

For communication among the 

components on the same installation, the 

ETR would maximize use of available 

communications assets, including cable. 

If communication cable is not available, 

new cable would be installed. 

Installation of new cable would be in 

existing conduit, if available. If not, 

new conduit would be constructed along 

rights-of-way. New conduit would be 

buried at a depth of approximately 3 

feet, where necessary.

The proposed action, among other 

things, is for communication cable(s) to 

be installed between support facilities 

and silos, as required. Cables would be 

installed in existing conduits, where 

available. If existing conduits are not 

available, the cable(s) would be 

installed in new conduits that would be 

placed in previously disturbed areas of 

soil (usually along the shoulders of 

existing roads) approved by the 

Vandenberg AFB Environmental 

Management Office where possible to 

avoid sensitive biological and cultural 

areas. 

Construction of the second RIDT would 

include installation among other things 

installation of communications lines and

equipment, uninterruptable power 

supply; and installation of a septic 

system.

Communications lines would be 

extended from an existing power line 

along El Rancho Road, including a cross 

connection with the existing RIDT. The 

lines would be placed in a buried 

flexible conduit, to be installed via 

trenching. Commercial power would be

brought to the second RIDT from an 

existing power line along the east side 

of El Rancho Road. The new line 

would be installed by a combination of 

boring and trenching. A new water line 

with pump station would be required to 

provide water sufficient for fire fighting. 

Trenching for the water line would be 

required and buried power lines would 

be extended to the new pump station 

from the second RIDT site.

Methods of 

Implementing 

the Action

Work with host installation or property owner to find 

suitable location and permission to install and operate 

utilities, equipment, or mobile antennas.

Work with host installation or property owner to identify 

applicable laws, regulations, SOPs, and existing areas 

with known natural and/or cultural resources and/or areas 

of environmental contamination to avoid.

Work with host installation or property owner to either 

review existing documentation and/or prepare necessary 

NEPA documentation.

Work with host installation or property owner to conduct 

any required site preparation activities and/or coordination 

with Federal and state agencies.

Same Same Same Same Same

Frequency of the 

Actions

Occasional. Occasional Occasional Occasional Occasional One time - complete

Applicable 

Regulations

NEPA, CWA, CAA, biological and cultural resource 

protection regulations, and other applicable state 

regulations.

Same Same Same Same Same

Applicable SOPs Installation/Manufacturer specific Same Same Same Same Same

83 October 2013
Benchmarking 

Categories MDA National Missile Defense Deployment 

Environmental Impact Statement 

July 2000

Ground-Based Midcourse Defense 

(GMD) Validation of Operational 

Concept (VOC) Environmental 

Assessment, March 2002, FONSI 

Signed

Ground-Based Midcourse Defense 

(GMD) Extended Test Range (ETR) 

Environmental Impact Statement, 

July 2003

Initial Defensive Operations 

Capability (IDOC) at Vandenberg 

Air Force Base Environmental 

Assessment, August 2003, FONSI 

Signed

Relocatable In-Flight Interceptor 

Communications System Data 

Terminal (IDT) #2 at Vandenberg Air 

Force Base, Supplemental 

Environmental Assessment, 

November 2007, FONSI Signed

Applicable 

CATEXs B-13

Timing and 

Context

Could occur any time of the year. MDA relies on 

installation’s infrastructure. 

Same Variable Same Same Same

Extraordinary 

Circumstances

Presence of cultural/historic resources threatened or 

endangered species, or environmental contamination.

Same Same Same. Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known 

significant impacts from these operations. 

No significant environmental impacts 

have been observed as a result of 

MDA’s construction and operation of 

NMD (now MDA) facilities, including 

the installation of utilities, 

communication systems, mobile 

antennas and similar electronic 

equipment.

These actions were completed over nine 

years ago and no adverse environmental 

impacts have been reported.

These actions were completed over 

eight years ago and no adverse 

environmental impacts have been 

reported from installation of utilities, 

communication systems, mobile 

antennas and similar electronic 

equipment.

These actions were completed over 

eight years ago and no adverse 

environmental impacts have been 

reported from installation of utility 

lines.

No significant environmental impacts 

have been observed as a result of 

MDA’s construction and operation of 

the IDT #2 and supporting facilities, 

including the installation of utility lines.

84 October 2013
B-14. Acquisition, installation or minor relocation, operation and maintenance or 

evaluation of physical security devices or controls to protect human or animal life and 

to enhance the physical security of existing critical assets in compliance with applicable 

Federal, tribal, state and local requirements to protect the environment. Examples 

include, but are not limited to:

a. Motion detection systems; 

b. Raptor electrocution prevention devices;

c. Lighting;

d. Remote video surveillance systems;

e. Access controls; and

f. Physical barriers, fences, grating, on or adjacent to existing facilities. 

(REC required.)

The Team found the physical security devices or controls contemplated by this CATEX are used 

at various MDA sites located on Services ranges or installations, or other Federal/commercial

sites. The Team noted these actions are not likely to alter or otherwise degrade the environment.

Most of the physical security devices or controls are commercially available products purchased 

in compliance with Federal Acquisition Regulations and installed and managed in compliance 

with accepted standards and protocols. These products are also used by private industry and 

other government agencies. 

The Team recognized this CATEX could involve actions involving one or more extraordinary 

circumstances (i.e., would adversely affect public health or safety; threatens a violation of 

Federal, state, or local environmental laws; or involves a site that includes wetlands not covered 

by a nation-wide or regional permit, endangered or threatened species, historical or archeological 

resources or hazardous wastes; etc.). Therefore, to ensure only those actions having negligible 

impacts on the human environment are contemplated, the Team proposed a REC be prepared to 

document no extraordinary circumstances exist and all CATEX use criteria are met, or whether 

the action requires further analysis through the NEPA process.

The Team determined the use of examples in this particular CATEX would be helpful to future 

users in clarifying the types of activities envisioned by the CATEX. In providing examples, the 

Team did not intend to either limit the CATEX to those activities or extend the CATEX to 

actions including extraordinary circumstances resulting in the activity having significant 

environmental effects. 

As documented in Table B-14.1 and B-14.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

85 October 2013
2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent and documented by a 

REC; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record 

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(41) Installation of devices to protect human or animal life (e.g., raptor electrocution 

prevention devices, fencing to restrict wildlife movement onto airfields, and fencing and 

grating to prevent accidental entry to hazardous areas).

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(10) Installation of devices to protect human or animal life, such as raptor electrocution 

prevention devices, fencing to restrict wildlife movement on to airfields, and fencing and 

grating to prevent accidental entry to hazardous areas. (Checklist required).

Federal Aviation Agency

Reference: FAA Order 5050.4A Chapter 3, Section 23

(a) (3) Installation of miscellaneous items including segmented circles, wind or landing 

direction indicators or measuring devices, or fencing. 

(a) (7) Landscaping generally, and landscaping or construction of physical barriers to 

diminish impact of airport blast and noise. 

(b) (2) Acquisition of: security equipment required by rule or regulation for the safety or 

security of personnel and property on the airport (14 CFR Part 107), safety equipment 

required by rule or regulation for certification of an airport (14 CFR Part 139) or snow 

removal equipment.

86 October 2013
Reference: FAA Order 1050.1E

Equipment and Instrumentation Actions 

9. Acquisition of security equipment required by rule or regulation for the safety or 

security of personnel and property on the airport or launch facility (14 CFR part 107, 

Airport Security), safety equipment required by rule or regulation for certification of an 

airport (14 CFR part 139, Certification and Operation: Land Airports Serving Certain Air 

Carriers) or licensing of a launch facility, or snow removal equipment. 

Department of Energy

Reference: 10 CFR1021 Subpart D Appendix B

B1.11 Installation of fencing, including that for border marking that will not adversely 

affect wildlife movements or surface water flow.

Missile Defense Agency Environmental Reviews

Reference: Ground-Based Midcourse Defense (GMD) Validation of Operational 

Concept (VOC) Environmental Assessment, March 2002, resulting in a FONSI

This EA analyzed among other things, components of site security to include a perimeter 

security fence, clear zone, security lighting, security standby power, intrusion detection 

system, and security patrol roads. The clear zone on the inner side of the fence would 

contain remotely operated lights and cameras. All vegetation would be cleared inside the 

security fence. Vegetation would be cleared to approximately 50 feet outside the security 

fence.

Thirteen broad areas of environmental consideration were considered and MDA 

determined no significant short- or long-term impacts would occur. No adverse 

environmental effects have been observed from installing or constructing these site 

security features.

Reference: Ground Based Midcourse Defense (GMD) Validation of Operational 

Concept (VOC) Supplemental Environmental Assessment, December 2002, resulting in 

a FONSI

This SEA analyzed among other things, proposed security enhancements to ensure 

adequate force protection, land security, and air safety measures for Fort Greely. This 

included the construction of security fences around three areas: the cantonment area, the 

southern boundary area, and the Allen Army Airfield. The fences would be 8-foot high 

chain-link fencing with barbed wire above. Gates would be sited to facilitate ease of 

operations, emergency crew access, and security. Vegetation would be cleared from 

designated areas inside and outside the fence boundaries. The security fences may be 

constructed in series or all at one time, depending on funding and additional security 

requirements.

87 October 2013
The resulting environmental analysis determined that no significant impacts would occur

affecting the quality of the human environment. No adverse environmental impacts have 

been observed as a result of construction of site security at Ft Greely.

Reference: Ground-Based Midcourse Defense (GMD) Extended Test Range (ETR) 

Final Environmental Impact Statement, July 2003

This EIS analyzed among other things, an expansion to the existing Intrusion Detection 

System to include all critical buildings associated with GMD operations. This expansion 

would include the installation of additional intrusion sensors, lighting, closed circuit 

television, and a monitor for sensors. Additional physical protection features would be 

constructed or placed to protect GMD assets. These may include, but are not limited to, 

fences, security lighting, bollards, tapered concrete barriers or similar devices, ditching 

and/or earth mounds, patrol roads, and observation tower(s).

Fourteen broad areas of environmental consideration were considered for assessing 

potential impacts and MDA determined that no significant impacts would occur from

implementing the proposed activities. No adverse environmental effects have been 

observed from installing or constructing site security features.

Reference: Missile Defense Agency Ground-Based Midcourse Defense (GMD) SeaBased X-Band (SBX) Radar Placement and Operation Adak, Alaska Environmental 

Assessment, October 2005, resulting in a FONSI

The EA analyzed the proposal to establish a security zone in accordance with 33 CFR 

Part 165, around the SBX in U.S. territorial waters while moored, anchored, or loitering 

in Kuluk Bay or Sitkin Sound. This security zone of approximately 500 yards would be 

required to ensure the physical protection of the SBX while positioned at the PSB. This 

security zone could include the installation and use of a floating security boom/fence for 

and/or operation of a security patrol boat. Transit through, or anchoring within, this 

security zone would be prohibited unless authorized by the appropriate SBX official.

Thirteen broad areas of environmental consideration were considered and MDA 

determined no significant short- or long-term impacts would occur. 

Reference: New Mission Beddown and Construction, Clear Air Force Station (AFS), 

Alaska Environmental Assessment, August 2012, resulting in a FONSI

The proposed action among other things is to expand and upgrade the current Protection 

Level -1(PL-1) restricted perimeter to a double fence configuration with a buried line 

sensor in the isolation zone. A new Entry Control Point (ECP) and parking area would 

be constructed. The perimeter fence would be integrated with the ECP sensors to provide 

a continuous line of detection for the restricted area perimeter. The east portion of the 

existing security fence would be removed and a new fence located further east from the 

existing facility. Vehicle gates, vehicle entrapment areas and the pedestrian entry point 

would be incorporated at the ECP. A new animal control fence would be located 30 ft 

88 October 2013
outside the site security fence around the entire facility. The existing interior fence 

would be extended to match the new fence. A buried Intrusion Detection sensor would 

be provided at the fence line along with site lighting. A 16 ft wide gravel road would be 

provided outside the animal control fence to facilitate security monitoring. The area 

between the site security and animal control fence would be a 4 inch gravel surface. 

Relocation of the site security fence would require moving the existing drainage basin 

from its present location to outside the new fence line. Approximately 0.25 acres would 

be cleared for the new retention pond. 

Seven broad areas of environmental consideration were considered and MDA determined 

no significant short- or long-term impacts would occur. This project is expected to begin

construction in 2013.

89 October 2013
Table B-14.1 Comparative Analysis of MDA CATEX B-14 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Navy U.S. Coast Guard Federal Aviation Agency Department of Energy

Notes

Applicable 

CATEXs B-14 (f)(41)

COMMANDANT INSTRUCTION 

M16475.1D, Categorical Exclusions

(10)

FAA Order 5050.4A Chapter 3, Section 23 and

FAA Order 1050.1E

10 CFR1021 Subpart D Appendix B

B1.11

Characteristics 

of the Action

Acquisition, installation or minor relocation, operation 

and maintenance or evaluation of physical security 

devices or controls to protect human or animal life and to 

enhance the physical security of existing critical assets in 

compliance with applicable Federal, tribal, state and local 

requirements to protect the environment. Examples 

include, but are not limited to: 

a) Motion detection systems, 

b) Raptor electrocution prevention devices, 

c) Lighting 

d) Remote video surveillance systems 

e) Access controls 

f) Physical barriers, fences, grating, on or adjacent to 

existing facilities. 

(REC required)

Installation and operation of these devices is consistent 

throughout the Military Services and security profession 

and is specified by DoD and Service requirements.

Lighting would be installed per local requirements to 

minimize “shine.”

Proposed action is limited to installation 

of devices to protect human or animal 

life (e.g., raptor electrocution prevention 

devices, fencing to restrict wildlife 

movement onto airfields, and fencing 

and grating to prevent accidental entry 

to hazardous areas). 

MDA has extensive experience working 

at U.S. Navy installations such as 

PMRF, HI; Point Mugu Sea Range, CA; 

San Nicolas Island, CA; and Dahlgren 

Naval Base, VA.

Proposed action is limited to installation 

of devices to protect human or animal 

life, such as raptor electrocution 

prevention devices, fencing to restrict 

wildlife movement on to airfields, and 

fencing and grating to prevent 

accidental entry to hazardous areas. 

(Checklist required).

a) (3) Installation of miscellaneous items 

including segmented circles, wind or landing 

direction indicators or measuring devices, or 

fencing. 

(a) (7) Landscaping generally, and landscaping or 

construction of physical barriers to diminish 

impact of airport blast and noise. 

(b) (2) Acquisition of: security equipment 

required by rule or regulation for the safety or 

security of personnel and property on the airport 

(14 CFR Part 107), safety equipment required by 

rule or regulation for certification of an airport (14 

CFR Part 139) or snow removal equipment. 

Equipment and Instrumentation Actions 

9. Acquisition of security equipment required by 

rule or regulation for the safety or security of 

personnel and property on the airport or launch 

facility (14 CFR part 107, Airport Security), 

safety equipment required by rule or regulation for 

certification of an airport (14 CFR part 139, 

Certification and Operation: Land Airports 

Serving Certain Air Carriers) or licensing of a 

launch facility, or snow removal equipment. 

Installation of fencing, including that for 

border marking that will not adversely 

affect wildlife movements or surface 

water flow.

Installation and operation of these 

devices is consistent throughout the 

Military Services and commercial sites

and is specified by DoD and Military 

Services requirements.

Although vegetation and critical areas of 

habitat would be avoided to the extent 

possible, security factors are the primary 

criterion in the placement of these 

devices.

Methods of 

Implementing 

the Action

Work with host installation or property owner to identify 

applicable laws, regulations, management plans, SOPs, 

and existing areas with known natural and/or cultural 

resources and/or areas of environmental contamination.

Work with host installation or property owner to either

review existing documentation and/or prepare necessary 

NEPA documentation.

Work with host installation or property owner to conduct 

any required coordination with Federal and state agencies

and obtain necessary permits.

Work with host installation or property to conduct any 

required site preparation activities.

Installation staff to identify applicable 

laws, regulations, management plans, 

SOPs, and existing areas with known 

natural and/or cultural resources and/or 

areas of environmental contamination to 

avoid.

Installation staff to either review 

existing documentation and/or prepare 

necessary NEPA documentation.

Installation staff conducts any required 

coordination with Federal and state 

agencies and obtains necessary permits.

Conduct any required site preparation 

activities.

Same Similar Similar

Frequency of the 

Actions

One time and usually associated with construction of new 

facilities or deployment of existing assets to new locations 

without existing fencing/security measures already in 

place. In many cases, fencing/security devices already 

exist on host installation/range. Therefore, this kind of 

activity does not occur frequently.

Greater Unknown, but expected to be greater Unknown, but expected to be greater Unknown Typical range operations subject to 

conditions of installation’s regulatory 

permits and management plans.

90 October 2013
Benchmarking 

Categories MDA U.S. Navy U.S. Coast Guard Federal Aviation Agency Department of Energy Notes

Applicable 

Regulations

NEPA, CERCLA, RCRA, CWA, CAA and other 

applicable Federal and state regulations, DoD and Service 

requirements, and industry standards.

Same Same Same Same

Applicable SOPs Installation/Manufacturer specific, but most are consistent 

among security devices.

Same Same Same Same

Timing and 

Context

This activity can occur at any time of the year in 

conjunction with test activities or where new site 

development is occurring. These activities are conducted 

at host installations or commercial properties where the 

same type of actions typically occurs.

Probably more frequent because of 

mission and scope of operations.

Unknown, but expected to be greater Unknown, but expected to be greater Unknown

Extraordinary 

Circumstances

Presence of cultural, historic, or biological resources or 

environmental contamination.

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known 

significant impacts from these types of operations. 

Same Same Same Same

91 October 2013
Table B-14.2 Comparative Analysis of MDA CATEX B-14 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Ground-Based Midcourse Defense 

(GMD) Validation of Operational 

Concept (VOC) Environmental 

Assessment, March 2002, FONSI 

Signed

Ground-Based Midcourse Defense 

(GMD) Validation of Operational 

Concept (VOC) Supplemental 

Environmental Assessment, 

December 2002, FONSI Signed

Ground-Based Midcourse Defense 

(GMD) Extended Test Range (ETR) 

Environmental Impact Statement, July 

2003

Missile Defense Agency Ground-Based 

Midcourse Defense (GMD) Sea-Based 

X-Band (SBX) Radar Placement and 

Operation Adak, Alaska Environmental 

Assessment, October 2005, FONSI 

Signed

New Mission Beddown and 

Construction, Clear Air Force Station 

(AFS), Alaska Environmental 

Assessment, August 2012, FONSI 

Signed Applicable 

CATEXs B-14

Characteristics of 

the Action

Acquisition, installation or minor relocation, 

operation and maintenance or evaluation of physical 

security devices or controls to protect human or 

animal life and to enhance the physical security of 

existing critical assets in compliance with applicable 

Federal, tribal, state and local requirements to 

protect the environment. Examples include, but are 

not limited to: 

a) Motion detection systems, 

b) Raptor electrocution prevention devices, 

c) Lighting 

d) Remote video surveillance systems 

e) Access controls 

f) Physical barriers, fences, grating, on or adjacent 

to existing facilities. 

(REC required). 

Installation and operation of these devices is 

consistent throughout the Military Services and 

security profession and is specified by DoD and 

Service requirements.

Lighting would be installed per local requirements 

to minimize “shine.”

Components of test site security would 

include a perimeter security fence, clear 

zone, security lighting, security standby 

power, intrusion detection system, and 

security patrol roads. The clear zone on 

the inner side of the fence would contain 

remotely operated lights and cameras. All 

vegetation would be cleared inside the 

security fence. Vegetation would be 

cleared to approximately 50 feet outside 

the security fence. 

The complete spectrum of MDA BMDS 

test activities were analyzed, including the 

construction of security fences around 

three areas: the cantonment area, the 

southern boundary area, and the Allen 

Army Airfield. 

The proposed action among other things 

was to expand the existing Intrusion 

Detection System to include all critical 

buildings associated with GMD 

operations. This expansion may include 

the installation of additional intrusion 

sensors, lighting, closed circuit television, 

and a monitor for the sensors. 

Numerous proposed activities were 

analyzed, including the installation of 

fences, security lighting, bollards, tapered 

concrete barriers or similar devices, 

ditching and/or earth mounds, patrol 

roads, and observation tower(s). 

Security vehicles would be on patrol day 

and night. Normal patrols would be 

confined to existing roads. 

A security zone would be established in 

accordance with 33 CFR Part 165, around 

the SBX in U.S. territorial waters while 

moored, anchored, or loitering in Kuluk 

Bay or Sitkin Sound. This security zone 

of approximately 500 yards would be 

required to ensure the physical protection 

of the SBX while positioned at the PSB. 

This security zone could include the 

installation and use of a floating security 

boom/fence for Alternative 1 mooring in 

Kuluk Bay around the SBX, and/or 

operation of a security patrol boat.

The proposed action among other things is 

to expand and upgrade the current PL-1 

restricted perimeter to a double fence 

configuration with a buried line sensor in 

the isolation zone. A new ECP and 

parking area would be constructed. 

Methods of 

Implementing the 

Action

Work with host installation or property owner to 

identify applicable laws, regulations, management 

plans, SOPs, and existing areas with known natural 

and/or cultural resources and/or areas of 

environmental contamination.

Work with host installation or property owner to 

either review existing documentation and/or prepare 

necessary NEPA documentation.

Work with host installation or property owner to 

conduct any required coordination with Federal and 

state agencies and obtain necessary permits.

Work with host installation or property to conduct 

any required site preparation activities.

Same Same Same Same Same

Frequency of the 

Actions

One time and usually associated with construction 

of new facilities or deployment of existing assets to 

new locations without existing fencing/security 

measures already in place. In many cases, 

fencing/security devices already exist on host 

installation/range. Therefore, this kind of activity 

does not occur frequently.

One time – complete. Except for 

maintenance of previously disturbed areas 

and routine operating of devices.

One time – complete. Except for 

maintenance of previously disturbed areas 

and routine operating of devices.

One time – complete. Except for 

maintenance of previously disturbed areas 

and routine operating of devices.

One time – complete. Except for 

maintenance of previously disturbed areas 

and routine operating of devices.

One time – complete. Except for 

maintenance of previously disturbed areas 

and routine operating of devices.

Applicable 

Regulations

NEPA, CERCLA, RCRA, CWA, CAA and other 

applicable Federal and state regulations, DoD and 

Service requirements, and industry standards.

Same Same Same Same. Same

92 October 2013
Benchmarking 

Categories MDA Ground-Based Midcourse Defense 

(GMD) Validation of Operational 

Concept (VOC) Environmental 

Assessment, March 2002, FONSI 

Signed

Ground-Based Midcourse Defense 

(GMD) Validation of Operational 

Concept (VOC) Supplemental 

Environmental Assessment, 

December 2002, FONSI Signed

Ground-Based Midcourse Defense 

(GMD) Extended Test Range (ETR) 

Environmental Impact Statement, July 

2003

Missile Defense Agency Ground-Based 

Midcourse Defense (GMD) Sea-Based 

X-Band (SBX) Radar Placement and 

Operation Adak, Alaska Environmental 

Assessment, October 2005, FONSI 

Signed

New Mission Beddown and 

Construction, Clear Air Force Station 

(AFS), Alaska Environmental 

Assessment, August 2012, FONSI 

Signed Applicable 

CATEXs B-14

Applicable SOPs Installation/Manufacturer specific, but most are 

consistent among security devices.

Same Same Same Same Same

Timing and 

Context

This activity can occurs at any time of the year in 

conjunction with test activities or where new site 

development is occurring. These activities are 

conducted at host installations or commercial 

properties where the same type of actions typically 

occurs.

24 hours/7 days a week operations Same Same

Extraordinary 

Circumstances

Presence of cultural, historic, or biological resources 

or environmental contamination.

Same Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no 

known significant impacts from these types of 

operations. 

No adverse environmental impacts have 

been observed since completion of the 

project over eight years ago.

These actions were completed over nine

years ago and no adverse environmental 

impacts have ever been reported from 

installation of this security fencing.

These actions were completed over nine

years ago and no adverse environmental 

impacts have ever been reported from 

installation of this security fencing.

The SBX was not deployed to the Adak, 

AK area.

Construction is expected to begin in 2013.

93 October 2013
B-15. Maintenance of archaeological, historical, and endangered or threatened species 

avoidance markers, fencing, and signs.

Natural resource management activities of the type contemplated by this CATEX would be 

undertaken to avoid impacts to native flora and fauna, archeological and historical sites. Any 

potential for environmental impacts would be small scale and confined to more localized 

impacts. Environmental impacts, if any, would be slight as any signage would impact a small 

area if at all and would be sited in close working coordination with host installation 

environmental management specialists so as to further minimize any potential biological or 

cultural resources impacts. Maintenance activities envisioned in this CATEX are intended to 

provide a benefit to the resource by providing added protection to existing sensitive resources by 

alerting personnel working in the area to avoid the sensitive areas. 

These activities would be conducted following existing installation or range standard operating 

procedures, as well as following any Integrated Natural Resource Management Plans (INRMP), 

Integrated Cultural Resources Management Plans (ICRMP) and applicable Federal, state and 

DoD regulations designed to protect the quality of the human environment. These procedures 

will prevent significant impacts because they dictate where and how safeguards will be placed to 

minimize impacts on the resources they are intended to protect. Failure to install these 

safeguards would create the possibility of serious environmental impacts. Failure to mark 

sensitive locations and prevent unlimited access could lead to trampling of sensitive vegetation, 

disturbance of protected wildlife, and damage of archaeological resources.

The Team reviewed other agencies’ CATEXs, particularly the Services where MDA would 

conduct theses type of activities on their ranges/installations. Because these activities: 1) are the 

same type of activities conducted by our Host installations and ranges at the similar locations,

and 2) must follow existing installation standard operating procedures and Federal, state, local, 

and tribal environmental requirements, the activities contemplated by this CATEX inherently do 

not have an individual or cumulative significant impact on the environment. 

As documented in Table B-15.1, the Team conducted a comparative analysis (or benchmarking) 

of MDA’s proposed CATEX to other applicable government organizations’ CATEXs. We 

compared the characteristics of the action, methods of implementing the action, frequency of the 

action, applicable regulations, applicable SOPs, timing and context, extraordinary circumstances, 

and known impacts from the proposed action. The Team determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent; and 

5) No known significant impacts are associated with this proposed activity. 

94 October 2013
Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record 

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(d) (5) Maintenance of archaeological, historical, and endangered/threatened species 

avoidance markers, fencing, and signs.

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(42) Reintroduction of endemic or native species (other than endangered or threatened 

species) into their historic habitat when no substantial site preparation is involved.

Federal Emergency Management Agency

Reference: 44 CFR § 10.8 (d) (2)

(xi) Planting of indigenous vegetation.

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(27) Natural and cultural resource management and research activities that are in 

accordance with inter-agency agreements and which are designed to improve or upgrade 

the USCG's ability to manage those resources.

95 October 2013
Table B-15.1 Comparative Analysis of MDA PCATEX B-15 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Coast Guard

Notes

Applicable CATEXs B-15 (d)(5) (f)(42) (27)

Characteristics of the 

Action

Maintenance of archaeological, historical, and endangered or threatened species 

avoidance markers, fencing, and signs.

Proposed action is limited to maintenance of 

archaeological, historical, and 

endangered/threatened species avoidance 

markers, fencing, and signs.

MDA has extensive experience working at 

U.S. Army installations such as the Ronald 

Reagan Test Site, USAKA; WSMR, NM; 

Redstone Arsenal, AL; Fort Greely, AK; 

Fort Drum, NY; and Fort Belvoir, VA.

Proposed action is limited to reintroduction 

of endemic or native species (other than 

endangered or threatened species) into their 

historic habitat when no substantial site 

preparation is involved.

MDA has extensive experience working at 

U.S. Navy installations such as PMRF, HI; 

Point Mugu Sea Range, CA; San Nicolas 

Island, CA; and Dahlgren Naval Base, VA.

Proposed action is limited to natural and 

cultural resource management and research 

activities that are in accordance with interagency agreements and which are designed 

to improve or upgrade the USCG's ability to 

manage those resources. 

Methods of 

Implementing the 

Action

These activities would be conducted following existing installation or range standard 

operating procedures, as well as following any INRMPs, ICRMPs and all applicable 

Federal, state, and DoD regulations designed to protect the quality of the human 

environment. 

Work with host installation to identify applicable laws, regulations, management plans 

and SOPs.

Work with host installation to obtain required permits, if any.

Work with host installation to either review existing documentation and/or prepare 

necessary NEPA and/or documentation.

Work with host installation to conduct any required coordination with Federal and state 

agencies.

Installation staff to identify applicable laws, 

regulations, management plans, SOPs.

Installation staff to either review existing 

documentation and/or prepare necessary 

NEPA documentation.

Installation staff conducts any required 

coordination with Federal and state agencies 

and obtains necessary permits.

Same Similar All these activities are conducted according 

to detailed regulations that are fundamentally 

consistent across Federal agencies. State 

regulations often differ on state specific 

archeological, historical, and endangered or 

threatened species found there.

Frequency of the 

Actions

Installation of these markers, fences, and signs is infrequent, especially since MDA 

operations usually avoid such sensitive areas. Also, signs and fencing have usually 

already been erected by the host installation. Maintenance may occur over the course of 

a year.

Greater Greater Unknown

Applicable 

Regulations

Federal and state natural and cultural resource protection regulations, and installation 

natural and cultural resource management plans required by these regulations.

Same Same Same

Applicable SOPs Installation specific and species specific. Same Same Same

Timing and Context These actions can occur at any time, but on host installations with developed natural 

and cultural resource programs.

Same

Same

Same

Extraordinary 

Circumstances

None. Same Same Same

Known Impacts from 

Proposed Action

After 20+ years of activities, MDA knows of no known impacts from these types of 

operations. 

Same Same Same

96 October 2013
B-16. Road or trail construction and repair on existing rights-of-ways or in previously 

disturbed areas which do not result in a change in functional use. Runoff, erosion, and 

sedimentation are controlled through implementation of best management practices

(BMP). (REC required.)

Activities contemplated by this CATEX are those undertaken within or near existing structures 

and facilities or along roads with existing rights-of ways or easements in a manner compliant 

with established Federal, state, local, and DoD requirements. The Team limited the scope of the 

activities contemplated by this CATEX to using existing rights-of-ways or previously disturbed 

areas. These areas would include properties having already been disturbed by prior use and the 

quality of biological resources would be minimal or non-existent and cultural resources are likely 

to have been previously identified and addressed, thereby eliminating potential biological or 

cultural resources impacts. The Team reasoned that road repair, by definition, could only occur 

in areas where a road previously existed. If an abandoned road was later reconstructed in the 

same right-of-way this would not likely disturb significant new areas of natural or cultural 

resources.

However, the Team realized if a road was abandoned for a long enough period of time, 

environmental conditions may revert back to a more natural state. In addition, old road right-ofways may have been established at a time when the potential for impacts to the human 

environment were not a factor in decision making. The majority of road reconstruction activities 

should occur on right-of-ways having been used in the recent past and not abandoned long 

enough to revert back to natural habitat. Because of these circumstances and the potential for 

actions to involve one or more extraordinary circumstances (i.e., would adversely affect public 

health or safety; threatens a violation of Federal, state, or local environmental laws; or involves a 

site that includes wetlands not covered by a nation-wide or regional permit, endangered or 

threatened species, historical or archeological resources or hazardous wastes), the Team

proposed a REC be prepared to document no extraordinary circumstances exist and all CATEXuse criteria are met.

Lastly, the Team recognized road reconstruction has the potential to generate indirect offsite 

environmental impacts. Therefore, the Team limited the scope of this CATEX to construction of 

roads where runoff, erosion and sedimentation issues are prevented through implementation of 

best management practices (BMPs). As a result of these limitations, the Team determined this 

CATEX contemplated activities that would inherently have no potential for significant impacts 

to the human environment. 

As documented in Table B-16.1, the Team conducted a comparative analysis (or benchmarking) 

of MDA’s proposed CATEX to other applicable government organizations’ CATEXs. We 

compared the characteristics of the action, methods of implementing the action, frequency of the 

action, applicable regulations, applicable SOPs, timing and context, extraordinary circumstances, 

and known impacts from the proposed action. The Team determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

97 October 2013
2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent and documented by a 

REC; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record 

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(c)(3) Road or trail construction and repair on existing rights-of-ways or on previously 

disturbed areas.

US Coast Guard

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(5) Routine repair and maintenance of buildings, roads, airfields, grounds, equipment, 

and other facilities which do not result in a change in functional use, or an impact on a 

historically significant element or setting.

Federal Aviation Agency

Reference: FAA Order 5050.4A Chapter 3, Section 23.

(5) Construction, relocation or repair of entrance and service roadway.

Missile Defense Agency Environmental Reviews

Reference: Missile Defense Agency Courtland Target Assembly Facility 

Environmental Assessment, October 2006, resulting in a FONSI

The EA analyzed among other things the construction of access roads, a rail spur, and 

utilities extensions. The proposed rail spur would extend 1.2 miles from the main rail 

line in the Town of Courtland and terminate at the proposed Motor Transfer Facility at 

the Courtland Facility. The rail spur would be constructed on top of an older, unused rail 

bed. A 120-foot long trestle also would be constructed to allow the rail spur to cross over 

a 12-foot deep ditch.

98 October 2013
An analysis of the proposed action has concluded there are no significant short-term or 

long-term effects to the environment. No adverse environmental impacts from road and 

rail construction at the Courtland Facility have been observed. Erosion, runoff and 

sedimentation BMPs have been observed to be effective in preventing siltation and runoff 

to adjacent streams.

Reference: REC GMD Entry Control Facility Relocations at Fort Greely, AK, 2002. 

Qualifies for Army CATEX (C)(3).

The proposed action included among other things construction of roads on previously 

disturbed land and upgrades of existing roads.

Reference: REC GMD South Construction Access Road at Fort Greely, Alaska, May 

2004. Qualifies for Army CATEX (C)(3).

The proposed action was to establish a southern access road to the GMD site following 

portions of the existing Fire Break Road. It would also include a new section of access 

road north of from the Fire Break Road into the GMD site.

Reference: REC AN/TPY-2 Radar Deployment at the Ted Stevens Marine Research 

Institute (TSMRI) on the National Oceanic and Atmospheric Administration (NOAA) 

Site in Juneau, Alaska in Support of Flight Test Ground-Based Interceptor (FTG) -04, 

May 2007. Qualifies for Army CATEX (C)(3).

The proposed action among other things was for development of a gravel parking lot for 

up to 15 vehicles and development of a gravel access road from the NOAA driveway, 

approximately 100 feet long.

Reference: REC Parking Lot Improvements at the Ted Stevens Marine Research 

Institute (TSMRI) on the National Oceanic and Atmospheric Administration (NOAA) 

Site in Juneau, Alaska, July 2008. Qualifies for Army CATEX (C)(3).

The proposed action is to improve the existing parking area adjacent to the MDA radar 

site by applying approximately 200 cubic yards of crushed stone to an area of 

approximately 100 feet by 60 feet.

99 October 2013
Table B-16.1 Comparative Analysis of MDA CATEX B-16 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Coast Guard Federal Aviation Agency

Notes

Applicable 

CATEXs B-16 (c)(3)

COMMANDANT INSTRUCTION M16475.1D, 

Categorical Exclusions

(5)

FAA Order 5050.4A Chapter 3, Section 23.

(a) (5)

Characteristics 

of the Action

Road or trail construction and repair on existing rights-of-ways 

in recently disturbed areas which have not reverted back to 

natural habitat and which do not result in a change in functional 

use. Runoff, erosion, and sedimentation issues are prevented 

through implementation of best management practices. (REC 

required).

BMPs include storm water, erosion, sedimentation and fugitive 

dust controls. These may include such features as berms, riprap, 

culverts, retention ponds, dust suppression during construction as 

well as reseeding of disturbed areas with native vegetation.

The impacts of construction machinery and crews would also be 

limited to the existing right-of-way, and would be controlled by 

runoff and sedimentation BMPs. Noise and air emissions would 

not be significant.

Proposed action is limited to road or trail 

construction and repair on existing rights-ofways or on previously disturbed areas.

MDA has extensive experience working at U.S. 

Army installations such as the Ronald Reagan 

Test Site, USAKA; WSMR, NM; Redstone 

Arsenal, AL; Fort Greely, AK; Fort Drum, NY; 

and Fort Belvoir, VA.

Proposed action is limited to routine repair and 

maintenance of buildings, roads, airfields, grounds, 

equipment, and other facilities which do not result 

in a change in functional use, or an impact on a 

historically significant element or setting.

Proposed action is limited to construction, 

relocation or repair of entrance and service 

roadway.

Methods of 

Implementing 

the Action

These activities would be conducted following existing 

installation or range standard operating procedures, as well as 

following any ICRMPs, INRMPs, CWA, CAA, and all 

applicable Federal, state, and DoD regulations designed to 

protect the quality of the human environment. These procedures 

will prevent impacts because they will dictate where and how 

construction and maintenance will be conducted so as to 

minimize impacts on the adjacent environment.

Work with host installation or property owner to identify 

applicable laws, regulations, management plans and SOPs.

Work with host installation or property owner to obtain required 

permits, if any.

Work with host installation or property owner to either review 

existing documentation and/or prepare necessary NEPA 

documentation.

Work with host installation to conduct any required coordination 

with Federal and state agencies.

Installation would conduct these activities 

following existing installation or range standard 

operating procedures, as well as following any 

ICRMPs, INRMPs, CWA, CAA, and all 

applicable Federal, state, and DoD regulations 

designed to protect the quality of the human 

environment. These procedures will prevent 

impacts because they will dictate where and how 

construction and maintenance will be conducted 

so as to minimize impacts on the adjacent 

environment.

Installation staff would identify applicable laws, 

regulations, management plans and SOPs.

Installation staff would obtain required permits, 

if any.

Installation staff would either review existing 

documentation and/or prepare necessary NEPA 

documentation.

Installations staff would conduct any required 

coordination with Federal and state agency.

Similar Similar All these activities are conducted according to 

detailed regulations that are fundamentally 

consistent across Federal agencies. State 

regulations could differ.

Frequency of the 

Actions

Road/trail construction is infrequent and usually occurs for new 

facilities without existing entrance roads. In most cases, roads 

have already been constructed by the host installation. 

Greater Greater Unknown

Applicable 

Regulations

Installation and range standard operating procedures, as well as 

ICRMPs, INRMPs, CWA, CAA, and all applicable Federal, 

state, and DoD regulations designed to protect the quality of the 

human environment

Same Sam Same

Applicable SOPs Installation specific. Same Same Same

100 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Coast Guard Federal Aviation Agency Notes

Timing and 

Context

These actions can occur at any time, but usually on host 

installations with developed natural and cultural resource

management programs.

Same Same

Same

Extraordinary 

Circumstances

Presence or resurgence of biological resources, wetlands and 

cultural/historic resources.

Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known 

significant impacts from these types of operations. 

Same Same Same

101 October 2013
B-17. Routine repair and maintenance of buildings, vessels, aircraft, grounds, and other 

facilities and equipment which do not result in a change in functional use or a 

significant impact on a historically significant element or setting. Examples include, but 

are not limited to: repair of roofs, doors, windows, or fixtures, localized pest 

management, and minor erosion control measures

Repair and maintenance activities contemplated by this CATEX are usual and customary 

activities conducted at all DoD Host installations, ranges and commercial/industrial sites on a 

day-to-day basis. These categories of actions were determined to have little potential for 

significant environmental impacts for the following reasons: 

1) Repair and maintenance activities follow standard operating procedures in accordance with 

appropriate laws and regulations to minimize impacts to the environment; 

2) These activities also are sufficiently small in scope and environmentally benign in character

so as not to result in significant environmental impacts; and

3) MDA has been conducting these type activities for 20 plus years without observing 

significant environmental impacts. 

The Team determined the use of examples in this particular CATEX would be helpful to future 

users in clarifying the types of activities envisioned by the CATEX. In providing examples, the 

Team did not intend to either limit the CATEX to those activities or extend the CATEX to 

actions including extraordinary circumstances resulting in the activity having significant 

environmental effects. 

In addition, this CATEX is supported by long-standing practices and use of similar CATEXs by 

the Services and their installations where MDA conducts the majority of its activities, as well as 

other federal agencies. The Team determined the characteristics of the activities at MDA were 

no different than those performed by other Federal agencies in general, as well as specifically 

related to the environment.

As documented in Table B-17.1 and B-17.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent; and 

102 October 2013
5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record 

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(g)(1) Routine repair and maintenance of buildings, airfields, grounds, equipment, and 

other facilities. Examples include, but are not limited to: Removal and disposal of 

asbestos-containing material (for example, roof material and floor tile) or lead-based 

paint in accordance with applicable regulations; removal of dead, diseased, or damaged 

trees; and repair of roofs, doors, windows, or fixtures (REC required for removal and 

disposal of asbestos-containing material and lead-based paint or work on historic 

structures).

(g)(3) Routine repair and maintenance of equipment and vehicles (for example, autos, 

tractors, lawn equipment, military vehicles, etc.) which is substantially the same as that 

routinely performed by private sector owners and operators of similar equipment and 

vehicles. This does not include depot maintenance of unique military equipment.

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(8) Routine repair and maintenance of buildings, facilities, vessels, aircraft, and 

equipment associated with existing operations and activities (e.g., localized pest 

management activities, minor erosion control measures, painting, refitting).

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.9. Repairing and replacing real property installed equipment.

A2.3.10. Routine facility maintenance and repair that does not involve disturbing 

significant quantities of hazardous materials such as asbestos and lead-based paint.

103 October 2013
U.S. Coast Guard

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(5) Routine repair and maintenance of buildings, roads, airfields, grounds, equipment, 

and other facilities which do not result in a change in functional use, or an impact on a 

historically significant element or setting.

(7) Routine repair and maintenance to waterfront facilities, including mooring piles, 

fixed floating piers, existing piers, and unburied power cables.

Federal Emergency Management Agency

Reference: 44 CFR10.8 (d) (2)

(x) Routine maintenance, repair, and grounds-keeping activities at FEMA facilities; 

(xv) Repair, reconstruction, restoration, elevation, retrofitting, upgrading to current 

codes and standards, or replacement of any facility in a manner that substantially 

conforms to the preexisting design, function, and location; [SE, in part]

Reference: Mobile Sensors Environmental Assessment, September 2005, resulting in 

a FONSI

MDA prepared this EA to analyze the use of land-based mobile sensors and airborne 

sensor systems at new and existing locations around the country. For land-based mobile 

sensors, activities included transporting sensors, site preparation, check out of equipment, 

activating the sensor and disassembling the sensors. Activities associated with airborne 

sensor systems included flying sensor systems to test support locations, setting up, 

checking out and performing maintenance on aircraft and airborne sensor systems, 

calibration of sensors, activation of sensors and flying airborne sensor systems back to 

bed down locations. Maintenance and repair of land-based sensor equipment, airborne 

sensor systems and aircraft were considered.

An analysis of the proposed action concluded there would be no significant short-term or

long-term effects to the environment or surrounding populations. MDA has conducted 

numerous test activities using mobile sensors in many locations including Alaska, Wake 

Island, and Hawaii. No adverse environmental impacts have been observed with the 

maintenance and repair of these assets.

Reference: Sea-Based X-Band (SBX) Radar Vessel Maintenance and Repair 

Environmental Assessment, April 2011, resulting in a FONSI

This EA analyzed the proposed maintenance activities at one of the contingency locations 

(Naval Station Everett (NSE) or Naval Air Station North Island (NASNI)), with a deepwater port capable of providing the required maintenance activities. Inspection, 

maintenance, and repair activities on the SBX Radar Vessel are similar to activities that 

are performed on all U.S. Navy ships. These activities include thruster maintenance, 

104 October 2013
painting, welding, blasting, sanding, plasma cutting, inspections, installation of new 

equipment, removal of broken and obsolete equipment, equipment calibration, washing 

of equipment and vessel, and purging of systems (e.g., cooling, sewage, water, etc.).

These activities would occur inside the vessel, outside the vessel (topside and below the 

waterline), and pier-side. Established standard industry BMPs would apply to these 

activities. The vessel would be in-port for maintenance and repair for approximately 3 

months, unless affected by operational needs or world events. 

Fourteen broad areas of environmental analysis were considered and MDA determined

no significant impacts would occur from maintenance activities associated with the 

proposed action. 

Reference: AF 813 KEI Booster Flight Vehicle Integration at Building 6527, 

December 2006. Qualifies for Air Force CATEX A2.3.10.

The proposed action is to remove the existing clean room and erect a tent enclosure on 

the exterior of the main bay door to provide additional floor space for the fully integrated 

vehicle.

Reference: REC Launch Control Facility Life Safety Upgrades at Meck Island, 

United States Army Kwajalein Atoll (USAKA), January 2007. Qualifies for Army 

CATEX (g)(1).

The proposed action was to install fire sprinklers, fire alarm system, and emergency exits 

and lighting; replace existing doors with fire rated doors; construct new fire rated corridor 

walls, and stairwell and door panic hardware for emergency egress; and replace the roof 

of the Launch Control Facility.

Reference: MFR Review of Environmental Consideration Related to Sea-Based XBand (SBX) Radar Vessel Maintenance and Upgrade at Vigor Shipyard, Seattle, WA, 

May 2011. 

MDA determined the proposed maintenance and upgrades to be performed on the SBX 

Radar Vessel were routine activities conducted at commercial facilities. Vigor Shipyard 

performs vessel maintenance, repair, upgrade and construction services for vessels of 

various sizes (including aircraft carriers) for government and commercial customers. 

Inspection, maintenance, and upgrade activities on the SBX Radar Vessel were 

determined to be similar activities that are performed on other U.S. Navy ships.

Reference: AF 813 MDA Consolidated Interceptor Facility at Building 1819 at VAFB, 

August 2012. Qualifies for Air Force CATEX A2.3.10.

The proposed action included among other things internal minor modifications along 

with electrical upgrades, communication upgrades, and security upgrades.

105 October 2013
Table B-17.1 Comparative Analysis of MDA CATEX B-17 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard

Notes

Applicable 

CATEXs B-17 (g)(1); (g)(3) (f)(8) A2.3.9; A2.3.10 (5); (7)

Characteristics 

of the action

Routine repair and maintenance of buildings, 

vessels, aircraft, grounds, and other facilities and 

equipment which do not result in a change in 

functional use or an impact on a historically 

significant element or setting. Examples include: 

repair of roofs, doors, windows, or fixtures, 

localized pest management and minor erosion 

control measures.

Maintenance activities of this type are usual and 

customary activities conducted at all DoD Host 

installations, ranges and industrial/commercial 

properties on a day-to-day basis and follow 

standard operating procedures and are performed 

in accordance with appropriate laws and 

regulations. These activities are sufficiently small 

in scope and environmentally benign in character.

For sea-going vessels, these activities may include 

engine maintenance, painting, welding, blasting, 

sanding, plasma cutting, inspections, installation 

of new equipment, removal of broken and 

obsolete equipment, equipment calibration, 

washing of equipment and vessel, and purging of 

systems (e.g., cooling, sewage, water, etc.). 

These activities would occur inside the vessel, 

outside the vessel (topside and below the 

waterline), and pier-side. Established standard 

industry BMPs would apply to these activities. 

Proposed action is limited to: (g)(1) Routine 

repair and maintenance of buildings, 

airfields, grounds, equipment, and other 

facilities. Examples include, but are not 

limited to: Removal and disposal of 

asbestos-containing material (for example, 

roof material and floor tile) or lead-based 

paint in accordance with applicable 

regulations; removal of dead, diseased, or 

damaged trees; and repair of roofs, doors, 

windows, or fixtures (REC required for 

removal and disposal of asbestos-containing 

material and lead-based paint or work on 

historic structures). 

(g)(3) Routine repair and maintenance of 

equipment and vehicles (for example, autos, 

tractors, lawn equipment, military vehicles, 

etc.) which is substantially the same as that 

routinely performed by private sector 

owners and operators of similar equipment 

and vehicles. This does not include depot 

maintenance of unique military equipment. 

MDA has extensive experience working at 

U.S. Army installations such as the Ronald 

Reagan Test Site, USAKA; WSMR, NM; 

Redstone Arsenal, AL; Fort Greely, AK; 

Fort Drum, NY; and Fort Belvoir, VA.

Proposed action is limited to routine repair 

and maintenance of buildings, facilities, 

vessels, aircraft, and equipment associated 

with existing operations and activities (e.g., 

localized pest management activities, minor 

erosion control measures, painting, 

refitting). 

MDA has extensive experience working at 

U.S. Navy installations such as PMRF, HI; 

Point Mugu Sea Range, CA; San Nicolas 

Island, CA; and Dahlgren Naval Base, VA.

Proposed action is limited: A2.3.9 

Repairing and replacing real property 

installed equipment. 

A2.3.10 Routine facility maintenance and 

repair that does not involve disturbing 

significant quantities of hazardous materials 

such as asbestos and lead-based paint. 

MDA has extensive experience working at 

U.S. Air Force Installations such as 

Vandenberg AFB, CA; Edwards AFB, CA; 

Wake Island; Clear AFS, AK; Elmendorf 

AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

Proposed action is limited to: (5) routine 

repair and maintenance of buildings, roads, 

airfields, grounds, equipment, and other 

facilities which do not result in a change in 

functional use, or an impact on a 

historically significant element or setting.

(7) Routine repair and maintenance to 

waterfront facilities, including mooring 

piles, fixed floating piers, existing piers, 

and unburied power cables. 

Methods of 

Implementing 

the action

Work with host installation or private property 

owner to identify applicable laws, regulations, 

management plans and SOPs and areas of known 

environmental contamination.

Work with host installation or private property 

owner to either review existing documentation 

and/or prepare necessary NEPA documentation.

Work with host installation to conduct any 

required coordination with Federal and state 

agencies.

Installation staff would identify applicable 

laws, regulations, management plans and 

SOPs and areas of known contamination.

Installation staff would either review 

existing documentation and/or prepare 

necessary NEPA documentation.

Installations staff would conduct any 

required coordination with Federal and state 

agency.

Same Same Similar All these activities are conducted according 

to detailed regulations that are 

fundamentally consistent across Federal 

agencies. State regulations could differr.

Frequency of the 

Actions

Repairs generally occur one time in one 

area/component; maintenance activities range in 

occurrence from daily, weekly, monthly, or 

annually depending on the system/component 

being serviced. 

Same Same Same Same Typical range operations subject to 

conditions of installation’s regulatory 

permits and cultural resource and hazardous 

material management plans and 

environmental restoration program.

Applicable 

Regulations

NEPA, NHPA, ARPA, CERCLA, CAA, CWA 

and other applicable Federal and state regulations, 

DoD and Military Service requirements, and 

industry standards.

Same Same Same Same

106 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard Notes

Applicable SOPs Installation/Manufacturer specific Same Same Same Same

Timing and 

Context

Can occur at any time of year. Activities occur on 

host military installations and ranges or 

commercial facilities.

Same Same Same Same

Extraordinary 

Circumstances

Demolition and removal of hazardous materials is 

addressed by CATEX B-19.

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no 

known significant impacts from these types of 

activities. 

Same Same Same Unknown (but expected to be similar)

107 October 2013
Table B-17.2 Comparative Analysis of MDA CATEX B-17 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Sea-Based X-Band (SBX) Radar Vessel Maintenance and Repair Environmental Assessment, April 2011. FONSI Signed

Mobile Sensors Environmental Assessment, September 2005. FONSI 

Signed

Applicable 

CATEXs B-17

Characteristics 

of the Action

Routine repair and maintenance of buildings, vessels, aircraft, grounds, and other 

facilities and equipment which do not result in a change in functional use or an impact 

on a historically significant element or setting. Examples include: repair of roofs, 

doors, windows, or fixtures, localized pest management and minor erosion control 

measures.

Maintenance activities of this type are usual and customary activities conducted at all 

DoD Host installations, ranges and industrial/commercial properties on a day-to-day 

basis and follow standard operating procedures and are performed in accordance with 

appropriate laws and regulations. These activities are sufficiently small in scope and 

environmentally benign in character.

For sea-going vessels, these activities may include engine maintenance, painting, 

welding, blasting, sanding, plasma cutting, inspections, installation of new equipment, 

removal of broken and obsolete equipment, equipment calibration, washing of 

equipment and vessel, and purging of systems (e.g., cooling, sewage, water, etc.). 

These activities would occur inside the vessel, outside the vessel (topside and below the 

waterline), and pier-side. Established standard industry BMPs would apply to these 

activities.

The proposed action analyzed in this EA is to conduct maintenance activities at one of 

the contingency locations (NSE or NASNI), with a deep-water port capable of 

providing the required maintenance activities. Inspection, maintenance, and repair 

activities on the SBX Radar Vessel are similar to activities that are performed on all 

U.S. Navy ships. These activities include thruster maintenance, painting, welding, 

blasting, sanding, plasma cutting, inspections, installation of new equipment, removal 

of broken and obsolete equipment, equipment calibration, washing of equipment and 

vessel, and purging of systems (e.g., cooling, sewage, water, etc.). These activities 

would occur inside the vessel, outside the vessel (topside and below the waterline), and 

pier-side. Established standard industry BMPs would apply to these activities. The 

vessel would be in-port for maintenance and repair for approximately 3 months, unless 

affected by operational needs or world events.

The proposed action analyzed the use of land-based mobile sensors and airborne sensor 

systems at new and existing locations around the country. For land-based mobile 

sensors, activities included transporting sensors, site preparation, check out of 

equipment, activating the sensor and disassembling the sensors. Activities associated 

with airborne sensor systems included flying sensor systems to test support locations, 

setting up, checking out and performing maintenance on aircraft and airborne sensor 

systems, calibration of sensors, activation of sensors and flying airborne sensor systems 

back to bed down locations. Maintenance and repair of land-based sensor equipment, 

airborne sensor systems and aircraft were considered.

Methods of 

Implementing 

the Action

Work with host installation or private property owner to identify applicable laws, 

regulations, management plans and SOPs and areas of known environmental 

contamination.

Work with host installation or private property owner to either review existing 

documentation and/or prepare necessary NEPA documentation.

Work with host installation to conduct any required coordination with Federal and state 

agencies.

Same Same

Frequency of the 

Actions

Repairs generally occur one time in one area/component; maintenance activities range 

in occurrence from daily, weekly, monthly, or annually depending on the 

system/component being serviced. 

One time Same

Applicable 

Regulations

NEPA, NHPA, ARPA, CERCLA, CAA, CWA and other applicable Federal and State 

Regulations, DoD and Service requirements, and industry standards.

Sa me Same

Applicable SOPs Installation/Manufacturer specific Same Same

Timing and 

Context

Can occur at any time of year. Activities occur on host military installations and ranges 

or commercial facilities.

Same Same

Extraordinary 

Circumstances

Demolition and removal of hazardous materials is addressed by CATEX B-19. Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known significant impacts from these 

types of activities. 

No adverse environmental impacts have been reported from the maintenance and repair 

of the SBX.

MDA has conducted numerous test activities using mobile sensors including 

modification, maintenance, and repair of facilities, vessels and aircraft and no 

environmental impacts have been observed.

108 October 2013
B-19. New construction or equipment installation or alterations (interior and exterior) to 

or construction of an addition to an existing structure that is similar to existing land use 

if the area to be disturbed has no more than 5.0 cumulative acres of new surface 

disturbance. The following conditions must be met:

a. The structure and proposed use are compatible with applicable Federal, tribal, 

state and local planning and zoning standards;

b. The site and scale of construction or improvement is consistent with those of 

existing, adjacent, or nearby buildings, and;

c. The construction or improvement will not result in uses that exceed existing 

support infrastructure capacities (roads, sewer, water, parking, etc.). 

This does not include construction of facilities for the transportation, distribution, use, 

storage, treatment, and disposal of solid waste or hazardous waste. (REC required.)

Alterations or construction activities contemplated by this CATEX are usual and customary 

activities conducted at all DoD host installations, ranges and commercial/industrial sites on a

routine basis. These categories of actions were determined to have little potential for 

significant environmental impacts. MDA reviewed other agencies’ CATEXs, particularly the 

Services where MDA typically conducts mission activities on their ranges/installations. The 

Team determined the above-enumerated CATEX encompassed activities that do not have an 

individual or cumulative significant impact on the environment because:

1) The activity is of a type that would be consistent with approved military installation or 

industrial site management plans and is thereby compatible with existing land use for the 

location;

2) Actions are areas where the quality of biological resources would be minimal or nonexistent and cultural resources are likely to have been previously identified and addressed

(or already disturbed), thereby eliminating potential biological or cultural resource 

impacts; 

3) The traffic impact (if any) would be limited and not exceed the capability of existing road 

networks;

4) Construction would be limited to a type and scale that does not exceed construction 

already existing in the area;

5) Construction would be conducted in accordance with applicable SOPs and BMPs;

6) Indirect (cumulative) impacts from associated infrastructure (e.g., utilities) would be

limited in scope; and

7) Certain types of facilities with potentially significant impacts, e.g., solid or hazardous 

waste facilities, are excluded from this CATEX.

Since new construction or improvements on land could involve numerous considerations, the 

Team took great care to establish limiting provisions to avoid the potential for significant 

impacts to the human environment. The limiting provisions were established based on similar 

limiting provisions found in other Federal agencies CATEXs or were added based on experience 

of MDA environmental staff to further avoid the potential for significant impacts to the human 

environment. 

109 October 2013
The Team recognized this CATEX could involve actions involving one or more extraordinary 

circumstances (i.e., would adversely affect public health or safety; threatens a violation of 

Federal, state, or local environmental laws; or involves a site that includes wetlands not covered 

by a nation-wide or regional permit, endangered or threatened species, historical or archeological 

resources or hazardous wastes; etc.). Therefore, to ensure only those actions having negligible 

impacts on the human environment are contemplated, the Team proposed a REC be prepared to 

document no extraordinary circumstances exist and all CATEX use criteria are met, or whether 

the action requires further analysis through the NEPA process.

As documented in Table B-18.1 and B-18.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent and documented by a 

REC; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(c)(1) Construction of an addition to an existing structure or new construction on a 

previously undisturbed site if the area to be disturbed has no more than 5.0 cumulative 

acres of new surface disturbance. This does not include construction of facilities for the 

transportation, distribution, use, storage, treatment, and disposal of solid waste, medical 

waste, and hazardous waste (REC required).

110 October 2013
(e)(4) Modification, product improvement, or configuration engineering design change 

to materiel, structure, or item that does not change the original impact of the materiel, 

structure, or item on the environment (REC required).

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(14) Alteration of and additions to existing buildings, facilities, structures, vessels, 

aircraft, and equipment to conform or provide conforming use specifically required by 

new or existing applicable legislation or regulations (e.g., hush houses for aircraft 

engines, scrubbers for air emissions, improvements to storm water and sanitary and 

industrial wastewater collection and treatment systems, and installation of firefighting 

equipment).

(15) The modification of existing systems or equipment when the environmental effects 

will remain substantially the same and the use is consistent with applicable regulations. 

(34) New construction that is similar to existing land use and, when completed, the use or 

operation of which complies with existing regulatory requirements (e.g., a building 

within a cantonment area with associated discharges/runoff within existing handling 

capacities).

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.8. Performing interior and exterior construction within the 5-foot line of a building 

without changing the land use of the existing building.

A2.3.14. Installing on previously developed land, equipment that does not substantially 

alter land use (i.e., land use of more than one acre). This includes outgrants to private 

lessees for similar construction. The EPF must document application of this CATEX on 

AF Form 813.

U.S. Coast Guard 

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(11) New construction in heavily developed portions of U.S. Coast Guard (USCG)

property, when construction, use and operation will comply with regulatory requirements 

and constraints. (Checklist required).

Federal Emergency Management Agency

Reference: 44 CFR10.8 (d) (2)

(x) Routine maintenance, repair, and grounds-keeping activities at FEMA facilities.

111 October 2013
(xv) Repair, reconstruction, restoration, elevation, retrofitting, upgrading to current codes 

and standards, or replacement of any facility in a manner that substantially conforms to 

the preexisting design, function, and location; [SE, in part].

(xvi) Improvements to existing facilities and the construction of small scale hazard 

mitigation measures in existing developed areas with substantially completed 

infrastructure, when the immediate project area has already been disturbed, and when 

those actions do not alter basic functions, do not exceed capacity of other system 

components, or modify intended land use; provided the operation of the completed 

project will not, of itself, have an adverse effect on the quality of the human environment;

Reference: Ground Operations and Testing in Support of the Airborne Laser (ABL) 

Program at Edwards Air Force Base, California Environmental Assessment, May 

2001, resulting in a FONSI

This EA evaluated the proposed construction and renovation activities and chemical 

storage at Edwards AFB for the ABL Program. The proposed action was the

construction and modification of the buildings that accommodate ABL ground 

operations, which included modification of the hangar to accommodate the 747 jet, laser 

installation, operational system check-out, construction of the Integrated Maintenance 

Facility (IMF) and installation of a toxic vapor capture system and/or a suitable heating, 

ventilation and air conditioning system.

The above construction activities could result in impacts to air quality, safety and 

occupational health, hazardous materials and waste, biological resources and geology and 

soils. Based on the finding of this environmental assessment and the mitigation which 

would be utilized during construction and operations, no significant impact would occur 

from the proposed action. This program was dismantled in 2011 without any observed 

adverse environmental impacts during construction or operation of the program.

Missile Defense Agency Environmental Reviews

Reference: Ground-Based Midcourse Defense (GMD) Initial Defensive Operations 

Capability (IDOC) at Vandenberg AFB Environmental Assessment, August 2003, 

resulting in a FONSI

Summary of Analysis as it pertains to this CATEX: Facility Modification and New 

Construction

The proposed action would use and/or modify four existing missile silos and other 

supporting facilities at Vandenberg AFB as part of the GMD IDOC. Several of these 

facilities may require interior modifications and the installation of additional 

infrastructure (i.e., security fencing, lighting, communications lines, water line upgrades, 

re-grading for proper storm drainage, septic tank and leach field, etc.). 

Fourteen broad areas were evaluated in the environmental analysis and MDA determined

no significant impacts would occur from activities associated with the Proposed Action. 

112 October 2013
Over eight years after modification and construction of these facilities, no adverse 

environmental impacts have been observed.

Reference: Mobile Sensors Environmental Assessment, September 2005, resulting in 

a FONSI

MDA prepared this EA to evaluate the potential environmental impacts of the use of 

mobile sensors (i.e., radar, telemetry, command and control, and optical systems) from 

land-based platforms and the use of airborne sensor systems. Land-based mobile sensors 

would be installed primarily on previously disturbed land or areas of similar land use. 

Land-based mobile sensors could be sited at numerous locations.

An analysis of the proposed action concluded there are no significant short-term or longterm effects to the environment or surrounding populations. MDA has conducted 

numerous test activities using mobile sensors in many locations including Alaska, Wake 

Island, and Hawaii. No adverse environmental impacts have been observed with site 

preparations of these assets.

Reference: Relocatable In-Flight Interceptor Communications System Data Terminal 

(RIDT) #2 at Vandenberg Air Force Base Supplemental Environmental Assessment,

November 2007, resulting in a FONSI

The proposed action is to construct and operate a second RIDT at a site adjacent to the 

existing RIDT along El Rancho Road on Vandenberg AFB. Construction of the second 

RIDT would include installation of a Relocatable IDT and communications equipment, 

within shelters, on concrete pads; backup power generator and uninterruptable power 

supply; communications hut; storage facility for spares; an above ground water tank for 

fire suppression, with on-site distribution system; and installation of a septic system for 

the existing ISFAC. 

The existing RIDT physical security facilities, including the fence, lighting, and sensors 

would be extended to surround the proposed second RIDT. Communications lines would 

be extended from an existing power line along El Rancho Road, including a cross 

connection with the existing RIDT. The lines would be placed in a buried flexible 

conduit, to be installed via trenching. Commercial power would be brought to the second 

RIDT from an existing power line along the east side of El Rancho Road. The new line 

would be installed by a combination of boring and trenching. A new water line with 

pump station would be required to provide water sufficient for fire fighting. Trenching 

for the water line would be required and buried power lines would be extended to the new 

pump station from the second RIDT site. 

Based on analysis of the proposed construction and operation of a second RIDT at 

Vandenberg AFB, this SEA identified no significant impacts affecting the quality of the 

human environment. No adverse environmental impacts were observed at this site during 

construction or since.

113 October 2013
Reference: REC Booster Vehicle (BV) Assembly Operations at Lockheed Martin 

Facilities, Courtland, AL, July 2002. Qualifies for Army CATEX (C)(1).

The proposed action was to make minor modifications to the existing Ordnance Building 

by: 1) installing an electric motor to a manually-operated bay door; 2) enhancing the 

compressed air system; 3) adding a 10 x 12 foot concrete pad adjacent to the building for 

the compressed air system; and 4) modifying an existing truck loading dock. A new test 

cell building (40 x 100 feet) would also be constructed.

Reference: AF 813 TPS-X Radar Deployment/Use, September, 2002. Qualifies for 

Air Force CATEX A2.3.14.

The proposed action included among other things: installation of a chain link perimeter 

fence, construction of a small concrete pad for a transformer or portable transformer 

trailer, siting of two modular offices with built-in toilet facilities with connection to local 

sewer or septic system.

Reference: REC Russian-American Observation Satellites (RAMOS), May 2003. 

Qualifies for Air Force CATEX A2.3.8.

The proposed action among other things was to conduct equipment modifications to 

existing equipment at Utah State University, Space Dynamics Lab and Arnold 

Engineering Development Center.

Reference: RCE White Sands Missile Range Missile Assembly Facility Upgrades for 

STANDARD Missile 3 Support, August, 2003. Qualifies for Navy CATEX (34).

The proposed action included the construction of a 9,182 square foot addition and 

improvements to the electrical and HVAC systems in the existing Missile Assembly 

Facility N300.

Reference: RCE Transportable Telemetry System Naval Air Station, Whidbey Island, 

Washington, April 2004. Qualifies for Navy CATEX (f)(34).

The proposed action included installing and upgrading existing utility and 

communication lines including minor trenching; replacing an existing transformer and 

utility connections installed in the parking area of Building 27; constructing several 

concrete footings in the parking area to act as supports and tie-downs for antennas; and 

several other minor actions.

Reference: AF 813 Construct and Operate Component Repair Laboratory in Bldg 369 

(IMF) at Edwards AFB, May 2004. Qualifies for AF CATEX A2.3.8 and A2.3.14.

The southwest bay of Building 269 at Edwards AFB would be modified into an 

approximately 1,100 square foot fluid component repair and cleaning shop. A clean 

room would also be installed.

114 October 2013
Reference: REC Construction and Operation of an Ancillary Radar Site at the Pacific 

Missile Range Facility, August 2004. Qualifies for Navy CATEX (f)(34).

The proposed action was to add a 60 x 80 meter, ancillary hardstand immediately east of 

and parallel to the primary THAAD hardstand. The ancillary radar site would also 

include a small storage building, limited fencing and a vehicle access road. All of these 

alterations would be made within the existing THAAD radar site footprint.

Reference: RCE MDA – 510, Telemetry Building at the Pacific Missile Range Facility 

(PMRF), Makaha Ridge, Kauai, HI, April 2005. Qualifies for Navy CATEX (34).

The proposed action was to erect a 2,000 square foot stand alone pre-engineered building 

at the PMRF Makaha Ridge telemetry complex.

Reference: AF 813 Temporary Use of Transportable Telemetry Equipment at 

Eareckson AFS in support of Flight Test 04-5, August 2005. Qualifies for Air Force 

CATEX A2.3.14.

The proposed action was to temporarily install and operate two transportable telemetry 

dishes and van; one telemetry van and one storage van; two SATCOM trailers with 

antennae; two 60 kW diesel electric generators with double-walled fuel tanks; and two 

connex trailers on previously disturbed land to support FT-4-5 mission.

Reference: REC GMD Entry Control Facility Relocations at Fort Greely, AK, August 

2005. Qualifies for Army CATEX (C)(1).

The proposed action among other things was for clearing and grubbing of up to five acres 

of land and construction of a new entry control facility and parking lot.

Reference: AF813 Removal of Utilities and Walls between Bays 1, 2, and 3 in 

Building 151 at Edwards AFB, October 2005. Qualifies for Air Force CATEX A2.3.8.

The proposed action was to remove utilities and wall between bays 1, 2, and 3 to allow 

the ABL program to proceed with future activities at this facility without unnecessary 

restrictions.

Reference: REC Construct Concrete Storage Pads at Wake Island, August 2006. 

Qualifies for Air Force CATEX A2.3.14.

The proposed action was to construct two 20 x 50 foot concrete storage pad on previously 

disturbed areas.

115 October 2013
Reference: REC Theater High Altitude Area Defense Radar Pad Extension at PMRF, 

September 2006. Qualifies for Navy CATEX (34).

The proposed action is to construct a 30 x 30 meter pad to move the radar forward. The 

pad extension would require modifications of the Protective Distribution System (PDS), 

which includes lightning protection and grounding systems. Modifying the PDS would 

require approximately 60 feet of trenching. All construction activities would occur in 

previously disturbed areas.

Reference: AF 813 KEI Booster Flight Vehicle Integration at Building 6527, 

December 2006. Qualifies for Air Force CATEX A2.3.8.

The proposed action included: removing an existing clean room from the high-bay and 

erect a temporary tent enclosure on the exterior of the main bay door to provide 

additional floor space for the fully integrated vehicle.

Reference: REC Entry Control Facility #1 Modification, Missile Defense Complex, Ft. 

Greely, AK, March 2007. Qualifies for Army CATEX (c)1.

The proposed action was to alter/add to the existing Entry Control Facility (ECF) #1 by: 

1) altering existing areas to enable parking of security reaction vehicles; 2) adding 

approximately 1,650 square feet to the ECF for an office and operations area; 3) adding 

approximately 2,300 square feet of special purpose assembly space; 4) constructing a 25 

x 50 foot leach field and installing a 2,000 gallon septic tank; and 5) adding water, sewer, 

gas, and electric utility service; paving, sidewalks, curbs and gutters; storm drainage; fire 

protection/alarm system; and communications systems to supporting facilities.

Reference: REC AN/TPY-2 Radar Deployment at the Ted Stevens Marine Research 

Institute (TSMRI) on the National Oceanic and Atmospheric Administration (NOAA) 

Site in Juneau, Alaska in Support of Flight Test Ground-Based Interceptor (FTG) -04, 

May 2007. Qualifies for Army CATEX (C)(1).

The proposed action among other things was to install a temporary security fence up to 8 

feet tall; install temporary 12 feet tall noise attenuation barriers; grade, fill and compact 1 

to 2 acres hardstand area; install two 6-foot satellite dishes for communication; and trim 

and/or top trees in approximately 1 acre of coastal fringe forest.

Reference: AF 813 XTR-1 Radar Site Preparations, Integration, and Testing at 

Massachusetts Institute of Technology Lincoln Laboratory (MIT/LL), June 2007. 

Qualifies for Air Force CATEX A2.3.14.

The proposed action is to construct a new 20 x 20 feet concrete pad. A few small trees 

(less than 2 inches in diameter) in a previously disturbed area adjacent to the proposed 

concrete pad may be removed. A perimeter security fence will be installed around the 

project area.

116 October 2013
Reference: AF 813 MDA/GMD, Vandenberg AFB – LF-23 (Bldg 1964) Pad 

Extension, August 2007. Qualifies for Air Force CATEX A2.3.8.

The proposed action was to extend the existing concrete pad an additional 20.8 feet to 

support the Strongback. The existing asphalt would be saw cut and replaced with 

concrete.

Reference: AF 813 Ballistic Missile Defense System Communications Support 

Complex – Transportable (BCSC-T), February 2008. Qualifies for CATEX AF 

A2.3.14.

The proposed action was to temporary site a transportable communications package 

consisting of three distinct transportable components: a protected communication control 

system, SATCOM, and power on previously disturbed land.

Reference: AF 813 MDA/GMD Extended Test Range - VAFB LF-24 Mods for Test, 

August 2008. Qualifies for Air Force CATEX A2.3.14.

The proposed action included the installation of a re-rad tower, installation of a guard 

shack with associated power and communications, and repaving of Parquee Road, the 

facility access road.

Reference: AF 813 MDA Modification of Bldg 988 for Administrative Space, March 

2009. Qualifies for Air Force CATEX A2.3.8.

The proposed action among other things included: 1) demolish interior dividers, 

flammable storage locker, elevated storage area, and the boiler room structure, 

2) demolish east-side building addition and concrete tank and sump, 3) repair roof and 

exterior siding, 4) install new interior architectural walls, doors, and associated items to 

create administrative areas, and 5) upgrade existing restroom.

Reference: AF 813 MDA- Lightning Protection System (LPS) Upgrades, March 2009. 

Qualifies for Air Force CATEX A2.3.8.

The proposed action included: 1) replacement of existing LPS equipment, 2) installation 

of new LPS equipment on existing facilities, 3) replacement of existing wooden poles and 

grounding rods, 3) installation of new poles and grounding rods, 4) connection of new 

and replaced equipment to the existing buried grounding system, and 5) removal of radio 

frequency towers at nine facilities at VAFB.

Reference: AF 813 AN/TPY-2 Radar Deployment at Wake Island in support of MDA 

Ballistic Missile Defense Systems (BMDS) Flight Tests, November 2009. Qualifies for 

Air Force CATEX A2.3.14.

The proposed action was to site, set up, calibrate and operate the AN/TPY-2 Radar, 

Defense Satellite Communication System, Transportable Telemetry System and 

117 October 2013
supporting communications equipment on previously disturbed land on Wake Island. 

Minor site clearing and preparation would occur and all cabling would either use existing 

buried conduit or be laid on the ground in protected cable trays.

Reference: RCE Construction of a Deckhouse Support Building, Relocatable 

Deckhouse, Installation and Checkout of an Aegis Ashore Weapons System at 

Lockheed Martin Mission Systems and Sensors (MS2), Moorestown, New Jersey, May 

2011. Qualifies for Navy CATEX (f)(34).

The proposed action among other things included: 1) grading, filling and compaction of 

approximately nine acres; 2) construction of a Deckhouse Support Building and 

installation of a relocatable Deckhouse with a footprint of approximately 1.4 acres; 3) use 

of a lay-down/staging area comprised of approximately 3 acres; 4) excavation for utilities 

to connect to existing utilities; and 5) construction of a separate, temporary construction 

site entrance.

Reference: REC Installation of Water Line along Mills Road and Relocation of 

Parking Lot and Ring Road North of Von Braun Complex, May 2012. Qualifies for 

Army CATEX (c)1.

The proposed action consisted of installing a 12 inch water line at the intersection of Neal 

Rd and Mills Rd to Von Braun IV; demolishing the existing ring road and relocation to 

the north, towards Neal Road; and construction of a new parking area. Total disturbance 

would be approximately 4.4 acres.

Reference: AF 813 MDA Consolidated Interceptor Facility at Building 1819 at VAFB, 

August 2012. Qualifies for Air Force CATEX A2.3.8.

The proposed action included among other things internal minor modifications and 

upgrades: 1) Removal of two small Peacekeeper-related items; 2) Installation and 

mounting of two missile “jack-able rail” work stands and installation of two portable 

“clean enclosures” around missile work stands; 3) Electrical upgrades; 4) Communication 

upgrades; 5) Security upgrades; and 6) Hypergol detection system installation.

 

118 October 2013
Table B- 18.1 Comparative Analysis of MDA CATEX B-18 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard

Notes

Applicable 

CATEXs B-18 (c)(1) and (e)(4) (f)(14), (15) and (34) A2.3.14 and A2.3.8 (11)

Characteristics 

of the Action

New construction or equipment installation 

or alterations (interior and exterior) to or 

construction of an addition to an existing 

structure that is similar to existing land use 

if the area to be disturbed has no more than 

5.0 cumulative acres of new surface 

disturbance. The following conditions must

be met: 

a) The site is in a developed area and/or 

previously disturbed site, 

g) The structure and proposed use are 

compatible with applicable Federal, tribal, 

state and local planning and zoning 

standards. 

h) The proposed use will not increase 

vehicular traffic beyond the capacity of the 

supporting road network to accommodate 

such an increase, 

i) The site and scale of construction or 

improvement is consistent with those of 

existing, adjacent, or nearby buildings, and, 

j) The construction or improvement will not 

result in uses that exceed existing support 

infrastructure capacities (roads, sewer, 

water, parking, etc.). 

This does not include construction of 

facilities for the transportation, distribution, 

use, storage, treatment, and disposal of solid

waste or hazardous waste. (REC required). 

Proposed action is limited to (c)(1) 

Construction of an addition to an existing 

structure or new construction on a 

previously undisturbed site if the area to be 

disturbed has no more than 5.0 cumulative 

acres of new surface disturbance. This does 

not include construction of facilities for the 

transportation, distribution, use, storage, 

treatment, and disposal of solid waste, 

medical waste, and hazardous waste (REC 

required). 

(e)(4) Modification, product improvement, 

or configuration engineering design change 

to materiel, structure, or item that does not 

change the original impact of the materiel, 

structure, or item on the environment (REC 

required). 

MDA has extensive experience working at 

U.S. Army installations such as the Ronald 

Reagan Test Site, USAKA; WSMR, NM; 

Redstone Arsenal, AL; Fort Greely, AK; 

Fort Drum, NY; and Fort Belvoir, VA.

Proposed action is limited to (14) Alteration 

of and additions to existing buildings, 

facilities, structures, vessels, aircraft, and 

equipment to conform or provide 

conforming use specifically required by 

new or existing applicable legislation or 

regulations (e.g., hush houses for aircraft 

engines, scrubbers for air emissions, 

improvements to storm water and sanitary 

and industrial wastewater collection and 

treatment systems, and installation of 

firefighting equipment). 

(15) The modification of existing systems 

or equipment when the environmental 

effects will remain substantially the same 

and the use is consistent with applicable 

regulations. 

(34) New construction that is similar to 

existing land use and, when completed, the 

use or operation of which complies with 

existing regulatory requirements (e.g., a 

building within a cantonment area with 

associated discharges/runoff within existing 

handling capacities). 

MDA has extensive experience working at 

U.S. Navy installations such as PMRF, HI; 

Point Mugu Sea Range, CA; San Nicolas 

Island, CA; and Dahlgren Naval Base, VA.

Proposed action is limited to A2.3.8. 

Performing interior and exterior 

construction within the 5-foot line of a 

building without changing the land use of 

the existing building. 

A2.3.14. Installing on previously 

developed land, equipment that does not 

substantially alter land use (i.e., land use of 

more than one acre). This includes outgrants 

to private lessees for similar construction. 

The EPF must document application of this 

CATEX on AF Form 813. 

MDA has extensive experience working at 

U.S. Air Force Installations such as 

Vandenberg AFB, CA; Edwards AFB, CA; 

Wake Island; Clear AFS, AK; Elmendorf 

AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

Proposed action is limited to new 

construction in heavily developed portions 

of USCG property, when construction, use 

and operation will comply with regulatory 

requirements and constraints. (Checklist 

required). 

Environmental impacts are limited by:

1) Actions are limited to previously 

disturbed sites or to new construction 

not exceeding 5 acres of new surface 

disturbance and land use is similar to 

existing land uses where no significant 

biological or cultural resources have 

been found to be present, thereby 

eliminating potential biological or 

cultural resource impacts. 

2) The activity is of a type already 

approved for the particular area by 

installation management plans and is 

thereby compatible with existing land 

use.

3) The traffic impact would be limited.

4) Construction would be limited to a 

type and scale that does not exceed 

construction already existing in the 

area.

5) Indirect (cumulative) impacts through 

associated infrastructure are also 

limited in scope.

6) Certain types of facilities with 

potentially significant impacts, i.e. 

solid or hazardous waste facilities are 

excluded from this CATEX.

Methods of 

Implementing 

the Action

Work with host installation or private 

property owner to identify applicable laws, 

regulations, management plans and SOPs 

and existing natural and cultural resources 

and areas of known environmental 

contamination.

Work with host installation or property 

owner to either review existing 

documentation and/or prepare necessary 

NEPA documentation.

Work with host installation or property 

owner to conduct any required coordination 

with Federal and state agencies.

Work with host installation to conduct any 

required site preparation activities.

Installation staff would identify applicable 

laws, regulations, management plans and 

SOPs and existing natural and cultural 

resources and areas of known 

environmental contamination.

Installation staff would either review 

existing documentation and/or prepare 

necessary NEPA documentation.

Installation staff would conduct any 

required coordination with Federal and state 

agency.

Installation staff to conduct any required 

site preparation activities.

Same Same Similar All these activities are conducted according 

to defined protocols that are fundamentally 

consistent across Federal agencies and by 

certified or otherwise qualified 

professionals.

Frequency of the 

Actions

Generally one time in one area. Same Same Same Same

119 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard Notes

Applicable 

Regulations

NEPA, ESA, NHPA, ARPA, CERCLA, 

CWA, CAA, and other applicable Federal 

and state regulations, DoD and Military

Service requirements, and industry 

standards.

Same, plus UES Same Same Same

Applicable SOPs Installation/Manufacturer specific and 

BMPs

Same Same Same Same

Timing and 

Context

Construction could occur any time of year 

in warm climates, but not winter time in 

Arctic areas.

MDA activities are conducted at host 

installations with same types of ongoing 

operations. MDA relies on installations 

infrastructure.

Same Same Same Same

Extraordinary 

Circumstances

Follow-on intrusive investigations and 

actions could be required if sensitive 

environmental, historical/cultural/biological 

resources, or hazardous material present, 

but would be covered by another 

appropriate CATEX or NEPA analysis.

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows 

of no known significant impacts from these 

types of operations. 

Same Same Same Unknown (but expected to be similar)

120 October 2013
Table B-18.2 Comparative Analysis of MDA CATEX B-18 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Ground Operations and Testing in Support of the Airborne Laser (ABL) Program at 

Edwards Air Force Base, California 

Environmental Assessment, May 2001, 

FONSI Signed

Ground-Based Midcourse Defense (GMD) Initial 

Defensive Operations Capability (IDOC) at 

Vandenberg AFB Environmental Assessment, 

August 2003, FONSI Signed

Mobile Sensors Environmental Assessment, 

September 2005, FONSI Signed

Relocatable In-Flight Interceptor 

Communications System Data Terminal (IDT) #2 

at Vandenberg Air Force Base, Supplemental 

Environmental Assessment, November 2007, 

FONSI Signed Applicable 

CATEXs B-18

Characteristics 

of the Action

New construction or equipment installation or alterations 

(interior and exterior) to or construction of an addition to an 

existing structure that is similar to existing land use if the area 

to be disturbed has no more than 5.0 cumulative acres of new 

surface disturbance. The following conditions must be met: 

a) The site is in a developed area and/or previously disturbed 

site, 

g) The structure and proposed use are compatible with 

applicable Federal, tribal, state and local planning and zoning 

standards. 

h) The proposed use will not increase vehicular traffic beyond 

the capacity of the supporting road network to accommodate 

such an increase, 

i) The site and scale of construction or improvement is 

consistent with those of existing, adjacent, or nearby 

buildings, and, 

j) The construction or improvement will not result in uses that 

exceed existing support infrastructure capacities (roads, sewer, 

water, parking, etc.). 

This does not include construction of facilities for the 

transportation, distribution, use, storage, treatment, and 

disposal of solid waste or hazardous waste. (REC required).

Proposed project activities in this environmental 

assessment would be located Edwards AFB. The 

proposed action was the construction and 

modification of the buildings that accommodate 

ABL ground operations, which includes

modification of the hangar to accommodate the 747, 

laser installation, operational system check-out, 

construction of the IMF and installation of a toxic 

vapor capture system and/or a suitable heating, 

ventilation and air conditioning system. 

MDA prepared this EA to evaluate the potential 

environmental impacts of facility modifications and 

new construction in order to use and/or modify four 

existing missile silos and other supporting facilities 

at Vandenberg AFB as part of the GMD IDOC. 

MDA prepared this EA to evaluate the potential 

environmental impacts of the use of mobile sensors 

(i.e., radar, telemetry, command and control, and 

optical systems) from land-based platforms and the 

use of airborne sensor systems. Land-based mobile 

sensors would be installed primarily on previously 

disturbed land or areas of similar land use. Landbased mobile sensors could be sited at numerous 

locations

Numerous proposed activities were analyzed, 

including construction of a second RIDT; 

communications equipment within shelters on 

concrete pads; backup power generator and 

uninterruptable power supply; communications hut; 

storage facility for spares; an above ground water 

tank for fire suppression, with on-site distribution 

system; and installation of a septic system for the 

existing ISFAC. 

Methods of 

Implementing 

the Action

Work with host installation to identify applicable laws, 

regulations, management plans and SOPs and existing natural 

and cultural resources and areas of known environmental 

contamination.

Work with host installation or private property owner to either 

review existing documentation and/or prepare necessary 

NEPA documentation.

Work with host installation or private property owner to 

conduct any required coordination with Federal and state 

agencies.

Work with host installation or private property owner to 

conduct any required site preparation activities.

Same Same Same Same

Frequency of the 

Actions

Generally one time in one area. Same Same Same Same

Applicable 

Regulations

NEPA, ESA, NHPA, ARPA, CERCLA, CWA, CAA, and 

other applicable Federal and State Regulations, DoD and 

Service requirements, and industry standards.

Same Same Sa me Same

Applicable SOPs Installation/Manufacturer specific and BMPs Same Same Same Same

121 October 2013
Benchmarking 

Categories MDA Ground Operations and Testing in Support of the Airborne Laser (ABL) Program at 

Edwards Air Force Base, California 

Environmental Assessment, May 2001, 

FONSI Signed

Ground-Based Midcourse Defense (GMD) Initial 

Defensive Operations Capability (IDOC) at 

Vandenberg AFB Environmental Assessment, 

August 2003, FONSI Signed

Mobile Sensors Environmental Assessment, 

September 2005, FONSI Signed

Relocatable In-Flight Interceptor 

Communications System Data Terminal (IDT) #2 

at Vandenberg Air Force Base, Supplemental 

Environmental Assessment, November 2007, 

FONSI Signed Applicable 

CATEXs B-18

Timing and 

Context

Construction could occur any time of year in warm climates, 

but not winter time in Arctic areas.

MDA activities are conducted at host installations with same 

types of ongoing operations. MDA relies on installations 

infrastructure.

Same Same Same Same

Extraordinary 

Circumstances

Follow-on intrusive investigations and actions could be 

required if sensitive environmental, 

historical/cultural/biological resources, or hazardous material 

present, but would be covered by another appropriate CATEX 

or NEPA analysis.

Same Same Same. Same.

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no known 

significant impacts from these types of operations. 

MDA is in the process of decommissioning this 

facility and no significant environmental impacts 

were observed as a result of the actions. 

No significant environmental impacts have been 

observed as a result of MDA’s refurbishment and 

the missile silos and supporting facilities at VAFB.

MDA has placed numerous mobile sensors on 

previously disturbed land or land with similar land 

uses and no significant environmental impacts have 

been observed.

No significant environmental impacts have been 

observed as a result of MDA’s construction of the 

IDT #2 and supporting facilities.

122 October 2013
B-19. Demolition of non-historic buildings, structures, or other improvements and repairs 

that result in disposal of debris there-from, or removal of a part thereof for disposal, in 

accordance with applicable regulations, including those regulations applying to removal 

of asbestos containing materials (ACM), polychlorinated biphenyls (PCBs), lead-based 

paint (LBP), and other special hazard items. (REC required.)

The types of activities contemplated by this CATEX are usual and customary activities routinely 

conducted on host installations, ranges or at commercial facilities and conform to the 

host/property owner’s master plans for the site. The activities would be performed in 

compliance with applicable environmental and safety requirements regarding the removal of 

ACM, PCBs, LBP and other hazardous substances ensuring proper handling, removal and 

disposal of these substances as well as control of potentially harmful air emissions. The 

activities would only occur in non-historic structures thereby preventing any impact to historic 

structures.

The Team found the U.S. Army, Navy, U.S. Coast Guard (USCG) and Federal Emergency 

Management Agency (FEMA) had CATEXs for the activities of removal or demolition, along 

with subsequent disposal of debris to permitted or authorized off-site locations, of non-historic 

buildings, structures, other improvements and/or equipment. The Army, Navy and USCG may 

perform these types of activities on U.S. government property under its control, while the FEMA

may authorize the performance of this type of activity through a public assistance program 

anywhere in the U.S. as a part of response and recovery to disasters. CATEXs from FEMA

include public assistance programs to be implemented in any part of the U.S. to assist in 

preparing and recovering from a disaster. 

MDA performs activities similar to the Army and Navy. The environmental assessments and 

FONSIs below describe some of those activities. Based upon this history of environmental 

analyses, the Team found actions of a similar nature, scope and intensity were performed by

MDA without significant environmental impacts. 

Since removal or demolition, along with subsequent disposal of debris, of non-historic buildings, 

structures, other improvements and/or equipment could involve numerous considerations, the 

Team proposed that a REC be prepared to document no extraordinary circumstances exist and all 

CATEX use criteria are met or whether the action requires further analysis with an EA or EIS.

In particular, the Team wanted to ensure the activities contemplated in this CATEX were 

performed in compliance with applicable environmental and safety requirements. 

As documented in Table B-19.1 and B-19.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

123 October 2013
2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent and documented by a 

REC; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(c)(2) Demolition of non-historic buildings, structures, or other improvements and 

disposal of debris there from, or removal of a part thereof for disposal, in accordance 

with applicable regulations, including those regulations applying to removal of asbestos, 

polychlorinated biphenyls (PCBs), lead-based paint, and other special hazard items (REC 

required).

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(35) Demolition, disposal, or improvements involving buildings or structures when done 

in accordance with applicable regulations including those regulations applying to removal 

of asbestos, PCBs, and other hazardous materials.

U.S. Coast Guard

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(13) Demolition or disposal actions that involve buildings or structures when conducted 

in accordance with regulations applying to removal of asbestos, PCB’s and other 

hazardous materials, or disposal actions mandated by Congress. In addition, if the 

building or structure is listed or eligible for listing, in the National Register of Historic 

Places, then compliance with section 106 of the National Historic Preservation Act is 

required. (Checklist required)

124 October 2013
Federal Emergency Management Agency

Reference: 44 CFR § 10.8 (d) (2)

(xii) Demolition of structures and other improvements or disposal of uncontaminated 

structures and other improvements to permitted off-site locations, or both; 

(xiii) Physical relocation of individual structures where FEMA has no involvement in the 

relocation site selection or development

Department of Energy

Reference: 10 CFR 1021

B1.23. Demolition and subsequent disposal of buildings, equipment, and support 

structures (including, but not limited to, smoke stacks and parking lot surfaces).

Missile Defense Agency Environmental Reviews

Reference: Draft Dismantlement or Destruction of Anti-Ballistic Missile Facilities, 

Stanley R. Mickelsen Safeguard Complex (SRMSC), North Dakota, 

Environmental Assessment, October 1999

The EA analyzed the proposal for the dismantlement or destruction (D/D) of some or all 

of the SRMSC facilities. ACM is found throughout facilities that would be dismantled or 

destroyed. A certified asbestos abatement contractor would remove and dispose of the 

ACM in accordance with Federal, state, and local requirements. The facilities that would 

be dismantled or destroyed may have been painted with LBP. Prior to disposal, the 

debris would be sampled to characterize the lead hazard in order to determine proper 

disposal procedures and locations. Regulated PCB equipment or contaminated debris 

found in the PAR building would follow the same characterization and disposal process 

as LBP debris. Water contaminated with chromium (or other pollutants) found in the 

Sprint or Spartan launchers would be removed, treated, and disposed of in accordance 

with applicable requirements. All hazardous materials and waste would be handled in 

accordance with Federal, state, and local requirements. If an NMD system is deployed at 

the SRMSC and new construction associated with deployment takes place concurrent 

with DoD activities, negligible increases in the use and generation of hazardous materials 

and waste could occur. During new NMD construction, all hazardous materials and 

waste would also be handled in accordance with Federal, state, and local requirements.

Fourteen broad areas of environmental analysis were considered and the resulting 

environmental analysis showed that no significant impacts would occur from the 

proposed dismantlement and destruction activities.

Reference: Alternate Boost Vehicle (ABV) Verification Tests Environmental 

Assessment, August 2002, resulting in a FONSI

This EA analyzed among other things, the removal and abatement of LBP, ACM, and 

PCBs as required before facility modifications occurred. The ABV program would

perform sampling and abatement for LBP, ACM, and PCBs as required prior to 

modification, using Vandenberg AFB-approved procedures. If any of the modifications 

125 October 2013
require the removal of these hazardous wastes, they would be properly disposed of in 

accordance with VAFB-approved plans developed by ABV program personnel, federal 

and state regulations, and the VAFB Hazardous Waste Management Plan.

Eleven broad resource areas were evaluated and based on the findings of this EA; no

significant impacts would result from the proposed action. No adverse environmental 

impacts have been observed.

Reference: Ground-Based Midcourse Defense (GMD) Initial Defensive Operations 

Capability (IDOC) at Vandenberg Air Force Base, August 2003, resulting in a FONSI

This EA analyzed among other things, the removal and abatement of LBP, ACM, PCBs 

and other hazardous substances as required before facility modifications occurred. The 

GMD program would perform sampling and abatement for LBP, ACM, PCBs and other 

hazardous substances as required. If any of the modifications require the removal of 

these hazardous wastes, they would be properly disposed in accordance with work plans 

developed by GMD personnel and approved by Vandenberg AFB 30th Civil Engineering 

Squadron/Environmental Management Flight. 

Fourteen broad resource areas were evaluated and based on the findings of this EA; no

significant impacts would result from the proposed action. No adverse environmental 

impacts have been observed. 

Reference: Draft Environmental Assessment for the Kinetic Energy Interceptor Initial 

Development and Test, April 2009

This EA analyzed the proposed action to conduct site modifications to several buildings 

for use by KEI. Older buildings proposed for KEI activities may contain hazardous 

materials used in their construction, such as ACM and LBP. At VAFB, LBP and ACM 

are managed in accordance with 30 SW Plan 32-1002 (Lead-Based Paint Management 

Plan), 30 SW Plan 32-1052-A (Asbestos Management Plan), 32-1052-B (Asbestos 

Operating Plan), and other applicable Federal, state, local, and USAF requirements.

Any removal of hazardous materials from the buildings and facilities would require 

containerizing and proper disposal in accordance with VAFB’s Hazardous Waste 

Management Plan (30 SW Plan 32-7043-A). Other non-hazardous construction and 

demolition debris would be managed in accordance with the disposal and recycling 

requirements specified in the base Solid Waste Management Plan (30 SW 32-7042). 

Prior to replacement of the HVAC system at Building 960, any R-22 

hydrochlorofluorocarbon refrigerant (a Class II ozone depleting substance) remaining in 

the old system would be recovered for proper disposal or reuse in accordance with AFI 

32-7086 (AFSPC Supplement 1).

During site modifications/construction activities, potential impacts could occur from the 

accidental release of fuel, anti-freeze, and oil from construction equipment. To minimize 

potential impacts, the construction contractor would be required to prepare a hazardous 

126 October 2013
material Spill Prevention and Response Plan and obtain concurrence from the base 

Environmental Office. The plan would include the implementation of BMPs, such as 

daily inspections of construction vehicles and equipment for fluid leaks, secondary 

containment provisions for equipment fueling sites, and proper handling and disposal of 

vehicle wastes. 

All hazardous materials and associated wastes would be responsibly managed in 

accordance with the well-established policies and procedures. All hazardous and nonhazardous wastes would be properly disposed of in accordance with applicable Federal, 

state, local, DoD, and USAF regulations.

An analysis of the proposed action concluded that its implementation will not have a

significant environmental impact on the human and natural environment, either by itself 

or cumulatively with other actions. Due to changes in program priorities, this project was 

halted and a FONSI was not signed.

127 October 2013
Table B-19.1 Comparative Analysis of MDA CATEX B-19 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Coast Guard Federal Emergency Management Agency

Notes

Applicable 

CATEXs B-19 (c)(2) (f)(35)

COMMANDANT INSTRUCTION 

M16475.1D, Categorical Exclusions

(13)

44 CFR § 10.8 (d) (2)

(xii) and (xiii)

Characteristics 

of the Action

Demolition or modification and repair of nonhistoric buildings, structures, or other 

improvements and repairs that result in 

disposal of debris there-from, or removal of a 

part thereof for disposal, in accordance with 

applicable regulations, including those 

regulations applying to removal of ACM, 

PCBs, LBP, and other special hazard items. 

(REC required.) 

The types of activities contemplated by this 

CATEX are usual and customary activities 

routinely conducted on host installations, 

ranges or at commercial facilities and conform 

to the host/property owner’s master plans for 

the site. 

The activities would be performed in 

compliance with applicable environmental and 

safety requirements regarding the removal of 

ACM, PCBs, LBP and other hazardous 

substances ensuring proper handling, removal 

and disposal of these substances as well as 

control of potentially harmful air emissions. 

The activities would only occur in nonhistoric structures thereby preventing any 

impact to historic structures.

Proposed action is limited to demolition 

of non-historic buildings, structures, or 

other improvements and disposal of 

debris there from, or removal of a part 

thereof for disposal, in accordance with 

applicable regulations, including those 

regulations applying to removal of 

asbestos, PCBs, LBP, and other special 

hazard items (REC required). 

MDA has extensive experience working 

at U.S. Army installations such as the 

Ronald Reagan Test Site, USAKA; 

WSMR, NM; Redstone Arsenal, AL; Fort 

Greely, AK; Fort Drum, NY; and Fort 

Belvoir, VA.

Proposed action is limited to demolition, 

disposal, or improvements involving 

buildings or structures when done in 

accordance with applicable regulations 

including those regulations applying to 

removal of asbestos, PCBs, and other 

hazardous materials. 

MDA has extensive experience working at 

U.S. Navy installations such as PMRF, HI; 

Point Mugu Sea Range, CA; San Nicolas 

Island, CA; and Dahlgren Naval Base, VA.

Proposed action is limited to demolition or 

disposal actions that involve buildings or 

structures when conducted in accordance 

with regulations applying to removal of 

asbestos, PCB’s and other hazardous 

materials, or disposal actions mandated by 

Congress. In addition, if the building or 

structure is listed or eligible for listing, in 

the National Register of Historic Places, 

then compliance with section 106 of the 

National Historic Preservation Act is 

required. (Checklist required).

Proposed action is limited to 

(xii) Demolition of structures and other 

improvements or disposal of 

uncontaminated structures and other 

improvements to permitted off-site 

locations, or both; 

(xiii) Physical relocation of individual 

structures where FEMA has no involvement 

in the relocation site selection or 

development

Methods of 

Implementing 

the Action

Work with host installation or property owner 

to find suitable sites for waste disposal.

Work with host installation or property owner 

to identify applicable laws, regulations, SOPs, 

BMPs, and reporting requirement.

Work with host installation or property owner 

to either review existing documentation and/or 

to prepare necessary NEPA documentation.

Work with host installation or property owner 

to conduct required consultations or obtain 

required permits and plans.

Work with host installation or property owner 

to conduct any required site preparation 

activities.

Record volumes of waste disposed of and 

track their disposal. 

Installation personnel would find suitable 

sites for waste disposal.

Installation personnel would identify 

applicable laws, regulations, SOPs, 

BMPs, and reporting requirement.

Installation personnel would either review 

existing documentation and/or to prepare 

necessary NEPA documentation.

Installation personnel would conduct 

required consultations or obtain required 

permits and plans.

Installation personnel would conduct any 

required site preparation activities.

Record volumes of waste disposed of and 

track their disposal. 

Same Same Similar Modification and demolition of structures 

on host installations, test ranges and 

industrial/commercial property is a usual 

and customary activity, which conforms to 

the installation/range’s Master Plan.

128 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Coast Guard Federal Emergency Management Agency Notes

Frequency of the 

Actions

Relatively infrequent, especially relative to 

Military Services that control a much larger 

volume and extent or real estate.

Greater Greater Greater Greater Typical operations subject to conditions of 

installation’s regulatory permits and master 

schedule.

Applicable 

Regulations

NEPA, CERCLA, RCRA, Toxic Substances 

Control Act (TSCA), CWA, CAA, biological 

and cultural resource protection regulations, 

and other applicable State Regulations.

Same, plus UES Same Same Same

Applicable SOPs Installation/Manufacturer specific SOPs, 

BMPs, local building codes and ordinances.

Same Same Same Same

Timing and 

Context

Could occur any time of the year. MDA relies 

on installation’s infrastructure and often their 

hazardous waste disposal contractors. 

Same Same Same Same

Extraordinary 

Circumstances

The Team recognized this CATEX could 

involve actions involving one or more 

extraordinary circumstances (i.e., would 

adversely affect public health or safety; 

threatens a violation of Federal, state, or local 

environmental laws applicable to MDA; or 

involves a site that includes wetlands not 

covered by a nation-wide or regional permit, 

endangered or threatened species, historical or 

archeological resources or hazardous wastes. 

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of 

no known significant impacts from these types 

of operations.

Same Same Same Unknown (but expected to be similar)

129 October 2013
Table B-19.2 Comparative Analysis of MDA CATEX B-19 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Draft Dismantlement or Destruction of AntiBallistic Missile Facilities, Stanley R. Mickelsen 

Safeguard Complex, North Dakota, 

Environmental Assessment, October 1999

Alternate Boost Vehicle (ABV) Verification 

Tests Environmental Assessment, August 

2002, FONSI Signed

Ground-Based Midcourse Defense (GMD) 

Initial Defensive Operations Capability 

(IDOC) at Vandenberg Air Force Base 

Environmental Assessment, August 2003, 

FONSI Signed

Draft Kinetic Energy Interceptor Initial 

Development and Test Environmental 

Assessment, April 2009

Applicable 

CATEXs B-19

Characteristics 

of the Action

Demolition or modification and repair of nonhistoric buildings, structures, or other improvements 

and repairs that result in disposal of debris therefrom, or removal of a part thereof for disposal, in 

accordance with applicable regulations, including 

those regulations applying to removal of asbestos, 

polychlorinated biphenyls (PCBs), lead-based paint, 

and other special hazard items. (REC required.) 

The types of activities contemplated by this CATEX 

are usual and customary activities routinely 

conducted on host installations, ranges or at 

commercial facilities and conform to the 

host/property owner’s master plans for the site. 

The activities would be performed in compliance 

with applicable environmental and safety 

requirements regarding the removal of asbestos, 

PCBs, lead-based paint and other hazardous 

substances ensuring proper handling, removal and 

disposal of these substances as well as control of 

potentially harmful air emissions. 

The activities would only occur in non-historic 

structures thereby preventing any impact to historic 

structures.

The proposed action was the D/D of some or all of 

the SRMSC facilities. ACM is found throughout 

facilities that would be dismantled or destroyed. The 

facilities that would be dismantled or destroyed may 

have been painted with LBP and regulated PCB 

equipment or contaminated debris may be present in 

the PARB. Water contaminated with chromium (or 

other pollutants) found in the Sprint or Spartan 

launchers would be removed, treated, and disposed 

of in accordance with applicable requirements. All 

hazardous materials and waste would be handled in 

accordance with Federal, state, and local 

requirements. 

The proposed action among other things, was 

conducting facility modifications including the 

removal and abatement of LBP, ACM, PCBs as 

required before facility modifications occurred. The 

ABV program would perform sampling and 

abatement for LBP, ACM, and PCBs as required 

prior to modification. If any of the modifications 

require the removal of these hazardous wastes, they 

would be properly disposed of in accordance with 

Vandenberg AFB-approved plans developed by 

ABV program personnel, federal and state 

regulations, and the Vandenberg AFB Hazardous 

Waste Management Plan.

The proposed action, among other things was the 

removal and abatement of LBP, ACM, PCBs and 

other hazardous substances as required before 

facility modifications occurred. The GMD program 

would perform sampling and abatement for LBP, 

ACM, PCBs and other hazardous substances as 

required. If any of the modifications require the 

removal of these hazardous wastes, they would be 

properly disposed in accordance with work plans 

developed by GMD personnel and approved by 

Vandenberg AFB 30th Civil Engineering 

Squadron/Environmental Management Flight.

The proposed action was to conduct site 

modifications to several buildings for use by KEI. 

Older buildings proposed for KEI activities may 

contain hazardous materials used in their 

construction, such as ACM and LBP. LBP and 

ACM would be managed in accordance with 30 SW 

Plan 32-1002 (Lead-Based Paint Management 

Plan), 30 SW Plan 32-1052-A (Asbestos 

Management Plan), 32-1052-B (Asbestos Operating 

Plan), and other applicable Federal, state, local, and 

USAF requirements.

Any removal of hazardous materials from the 

buildings and facilities would require containerizing 

and proper disposal in accordance with Vandenberg 

AFB’s Hazardous Waste Management Plan. Other 

non-hazardous construction and demolition debris 

would be managed in accordance with the disposal 

and recycling requirements specified in the base 

Solid Waste Management Plan.

Methods of 

Implementing 

the Action

Work with host installation or property owner to find 

suitable sites for waste disposal.

Work with host installation or property owner to 

identify applicable laws, regulations, SOPs, BMPs, 

and reporting requirement.

Work with host installation or property owner to 

either review existing documentation and/or to 

prepare necessary NEPA documentation.

Work with host installation or property owner to 

conduct required consultations or obtain required 

permits and plans.

Work with host installation or property owner to 

conduct any required site preparation activities.

Record volumes of waste disposed of and track their 

disposal.

Same Same Same Same

Frequency of the 

Actions

Relatively infrequent, especially relative to Military 

Services that control a much larger volume and 

extent or real estate.

One time One time - completed One time - completed One time 

130 October 2013
Benchmarking 

Categories MDA Draft Dismantlement or Destruction of AntiBallistic Missile Facilities, Stanley R. Mickelsen 

Safeguard Complex, North Dakota, 

Environmental Assessment, October 1999

Alternate Boost Vehicle (ABV) Verification 

Tests Environmental Assessment, August 

2002, FONSI Signed

Ground-Based Midcourse Defense (GMD) 

Initial Defensive Operations Capability 

(IDOC) at Vandenberg Air Force Base 

Environmental Assessment, August 2003, 

FONSI Signed

Draft Kinetic Energy Interceptor Initial 

Development and Test Environmental 

Assessment, April 2009

Applicable 

CATEXs B-19

Applicable 

Regulations

NEPA, CERCLA, RCRA, TSCA, CWA, CAA, 

biological and cultural resource protection 

regulations, and other applicable State Regulations.

Same Same Same Same

Applicable SOPs Installation/Manufacturer specific SOPs, BMPs, 

local building codes and ordinances.

Same Same Same Same

Timing and 

Context

Could occur any time of the year. MDA relies on 

installation’s infrastructure and often their hazardous 

waste disposal contractors. 

Same Same Same Same

Extraordinary 

Circumstances

The Team recognized this CATEX could involve 

actions involving one or more extraordinary 

circumstances (i.e., would adversely affect public 

health or safety; threatens a violation of Federal, 

state, or local environmental laws applicable to 

MDA; or involves a site that includes wetlands not 

covered by a nation-wide or regional permit, 

endangered or threatened species, historical or 

archeological resources or hazardous wastes. 

Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of activities, MDA knows of no 

known significant impacts from these types of 

operations.

MDA did not locate facilities on this site, therefore 

did not dismantle any facilities 

No adverse environmental effects have been 

observed from silo reactivation and supporting 

facility modification since project construction.

No adverse environmental effects have been 

observed from silo reactivation and supporting 

facility modification since project construction.

Due to changes in program priorities, this project 

was halted and a FONSI was not signed.

131 October 2013
B-20. Research, testing, and operations conducted at existing facilities and plants or 

laboratories (including contractor-operated laboratories and plants) and in compliance 

with all applicable safety, environmental and natural conservation laws. Examples 

include, but are not limited to: wind tunnels, high energy lasers, remote sensing 

instruments, vacuum chambers, high altitude simulator facilities, and propellant testing 

facilities.

Research, development, testing, and evaluation (RDT&E) activities or laboratory operations 

contemplated by this CATEX are those that would be undertaken at facilities operating under 

stringent requirements designed to protect the quality of the human environment. Examples of 

these types of activities include research, testing and operation of sensors (radars) and their 

components, lasers, propellants, missile payloads, communication systems, simulated high 

altitude components and material testing. These requirements include strict operating procedures 

governing laboratory and plant operations and personnel responsibilities. These activities are 

conducted either at military facilities or government defense contractor owned facilities. These 

facilities have established and longstanding environmental programs governing air emissions, 

wastewater and storm water discharges, solid and hazardous waste management and disposal, 

and natural and cultural resources protection. Strict procedures to protect workers and the 

general public from ionizing and non-ionizing radiation are in place. These facilities have 

established environmental management programs in place that are subject to routine 

environmental compliance audits from both internal and external auditors to ensure requirements 

governing air emissions, wastewater and storm water management, hazardous materials and 

waste management, and cultural and natural resources management, etc. are met. Additionally, 

where appropriate, MDA conducts routine compliance assessments, health and safety, and 

quality control audits at these facilities. Because of these controls, these types of activities have 

little potential for significant environmental impacts. 

The Team specifically limited this CATEX to actions conducted at existing facilities, actions 

consistent with previously established safety levels and in compliance with Federal, state, and 

local requirements to protect the environment, and actions conducted in a manner resulting in no, 

or de minimis change in the use of the facility. This was done to ensure no potential for 

significant environmental impacts. Further, this CATEX expressly does not include actions that 

would substantially increase the extent of potential environmental impacts or is controversial. 

As documented in Table B-20.1 and B-20.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

132 October 2013
3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent; and 

5) No known significant impacts are associated with this proposed activity. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record 

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(h) (5) Research, testing, and operations conducted at existing enclosed facilities 

consistent with previously established safety levels and in compliance with applicable 

federal, state, and local standards. For facilities without existing NEPA analysis, 

including contractor-operated facilities, if the operation will substantially increase the 

extent of potential environmental impacts or is controversial, an EA (and possibly an 

EIS) is required.

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(17) New activities conducted at established laboratories and plants (including contractoroperated laboratories and plants) where all airborne emissions, waterborne effluent, 

external ionizing and non-ionizing radiation levels, outdoor noise, and solid and bulk 

waste disposal practices are in compliance with existing applicable Federal, state, and 

local laws and regulations.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.27. Normal or routine basic and applied scientific research confined to the 

laboratory and in compliance with all applicable safety, environmental, and natural 

resource conservation laws.

U.S. Coast Guard

Reference: COMMANDANT INSTRUCTION M16475.1D, Categorical Exclusions

(28) Contracts for activities conducted at established laboratories and facilities, to include 

contractor-operated laboratories and facilities, on USCG-owned property where all 

airborne emissions, waterborne effluents, external radiation levels, outdoor noise, and 

solid and bulk waste disposal practices are in compliance with existing applicable 

Federal, state, and local laws and regulations. (Checklist required.)

133 October 2013
Anima Plant Health Inspection Service 

Reference: 7 CFR 372.5 (c) 

(2) Research and development activities. (i) Activities that are carried out in laboratories, 

facilities or other areas designed to eliminate the potential for harmful environmental 

effects--internal or external--and to provide for lawful waste disposal (ii) Examples of 

this category of actions include: (A) The development and/or production (including 

formulation, repackaging, movement, and distribution) of previously approved and/or 

licensed program materials, devices, reagents, and biologics; (B) Research, testing, and 

development of animal repellents; and (C) Development and production of sterile insects.

Environmental Protection Agency

Reference: 40 CFR 6 Subpart G Sec. 6.704 Categorical Exclusions

(b) The following specialized categories of ORD actions are eligible for categorical 

exclusion from a detailed NEPA review: (4) Projects conducted completely within a 

contained facility, such as a laboratory or other enclosed building, where methods are 

employed for appropriate disposal of laboratory wastes and safeguards exist against 

hazardous, toxic, and radioactive materials entering the environment. Laboratory 

directors or other appropriate officials must certify and provide documentation that the 

laboratory follows good laboratory practices and adheres to applicable Federal statutes, 

regulations and guidelines.

Missile Defense Agency Environmental Reviews

Reference: Final Programmatic Environmental Assessment (PEA) of Propulsion 

Testing Capabilities at the Phillips Laboratory, Edwards Air Force Base, California, 

January 1998, resulting in a FONSI

This PEA analyzed the proposed increase in propellant testing operations in Phillips 

Laboratory at Edwards AFB, California; conduct rocket propulsion basic exploratory and 

developmental research; execute the research, and exploratory development and 

advanced development programs for interdisciplinary space technology and rocket 

programs; provide support and capability for other governmental agencies and private 

industries to conduct contracted and in-house research and development; and ensure 

compliance with applicable environmental laws and regulation.

Thirteen broad resource areas were considered and it was determined no significant 

environmental impacts associated with implementation of the proposed action 

Alternative. No adverse environmental impacts resulting from MDA activities have been 

observed at Phillips Laboratory.

Reference: Vertical Gun Test Environmental Assessment, May 2004, resulting in a 

FONSI

This EA analyzed the proposal to conduct up to six vertical gun tests within a two-week 

period at the Energetic Materials Research and Testing Center at New Mexico Institute of 

Mining and Technology, located near Socorro, NM. Canisters containing tributyl 

134 October 2013
phosphate (TBP) would be launched at the 3K North site. The canisters would contain 

approximately 110 pounds of TBP thickened using polybutyl methacrylate enhanced with 

blue dye for observation purposes. A small amount of explosives would be used to 

rupture the canister tanks during ascent at an altitude of approximately 1,640 feet, 

resulting in the creation of a short-lived aerosol debris cloud and the subsequent 

dispersion of TBP droplets.

A suite of remote sensing instruments operated by the USAF Research Laboratory would 

be employed to monitor firing of the vertical gun, the TBP aerosol debris cloud that 

would form upon rupture of the launched canister, and the resulting TBP droplet debris 

fallout, including droplet formation, size, and spatial distribution. 

Thirteen resource areas were considered in the EA and MDA determined that no 

significant impacts would result from the proposed action. No adverse environmental 

impacts have occurred from MDA activities at the test site.

Reference: Missile Defense Agency MUDPACK II Test Environmental Assessment, 

April 2005, resulting in a FONSI

This EA analyzed activities at the High Energy Laser System Test Facility (HELSTF), 

located at WSMR in New Mexico.

The purpose of the proposed tests was to characterize and quantify 1) the effects of a laser

directed at the rocket motor of a ballistic missile during its boost phase, and 2) the 

resulting effect on the payload (i.e., bomblets or an inert mass). The analysis would 

include observing the effect of firing the laser at the rocket motor and documenting the

debris characteristics and dispersion pattern.

The proposed action was to perform a series of tests that involved lasing a restrained 

thrusting solid rocket motor containing either a payload of inert bomblets filled with 

Bacillus thuringiensis powder (a commonly used organic insecticide), or an inert mass.

Thirteen resource areas were considered and the resulting environmental analysis showed

that no significant short-term or long-term effects to the environment or surrounding 

populations would occur from the proposed tests. No adverse environmental impacts 

from MDA test activities have occurred at the HELSTF.

Reference: Construction of a High Altitude Simulation Chamber and Conduct of 

MDA Lethality Tests at Porton Down, UK, EO 12114 Environmental Review, October 

2002

While not a NEPA document, this Environmental Review (ER) is referenced to 

demonstrate no environmental impacts were anticipated as a result of this type of activity.

This ER analyzed the construction of a steel linear chamber/tube approximately 425 ft 

long with vacuum pumps and supporting infrastructure to simulate a high altitude 

135 October 2013
environment for testing the dispersal of chemical agents released from high altitude (up 

to 100 km) ballistic missile intercepts. This vacuum chamber would serve as an 

experimental laboratory to conduct approximately 100 dispersion tests over four years. 

Live agents would be produced at Porton Down and transported, securely stored (and 

guarded by Ministry of Defense, United Kingdom (MODUK forces)), and tested within 

the compound. Chemical wastes from decontamination and contaminated materials 

would be incinerated onsite at Porton Down using the UK’s Safe Working Practices 

standards. All live agents would be produced, used in tests and disposed of, within the 

confines of Porton Down. Therefore, there would be no significant increased impacts to 

the environment or public health in the UK. During testing and decontamination 

activities within the High Altitude Simulator Facility all personnel would wear the 

appropriate personal protective equipment; comply with MODUK laboratory, 

transportation, storage, and security protocols; and execute the UK Safe Working 

Practice standards. Application of the Safe Working Standards to the lethality test 

processes would further minimize environmental, safety, occupational and public health 

risks. Lastly, live agent testing at Porton Down would be viewed as a normal business 

activity that would be tightly controlled, directly supports combat operations of the UK 

and, would authorized by the Parliament. 

The MODUK prepared an environmental analysis of existing operations, and concluded 

its action has no significant effect on the environment. No adverse environmental impacts 

resulting from MDA activities at Porton Down have been observed.

Reference: REC Russian-American Observation Satellites (RAMOS), May 2003. 

Qualifies for Air Force CATEX A2.3.27 and Navy CATEX (17).

The proposed action was to include design, fabrication, integration, test, launch, and 

operation of two satellites that would conduct a series of scientific experiments over a 

two-year mission life.

Reference: REC Laboratory Experimentation and Analysis in Support of Corporate 

Lethality Program, June 2003. Qualifies for Air Force CATEX A2.3.27.

The proposed action and ongoing activities conducted at a federally funded research and 

development centers, DoD facilities, and academic institutions included the investigation 

of the intercept of various threat payloads at different altitudes and speeds. This included 

laboratory experimentation of developing equation of state data used in simulated 

engagement, predictive tools, scaled impact studies with high-speed gas guns, 

comparisons of actual threat agents to simulants, determining thermo-mechanical 

properties of agents and simulants, observing and analyzing hypervelocity impact flash 

for kill assessment, using vertical wind tunnels to characterize agent/simulant 

aerodynamic response and slide wire testing to characterize stimulant viscoelasticity.

136 October 2013
Reference: REC Use of Tributyl Phosphate (TBP) in Bulk Chemical Aerobreakup 

Experiments at New Mexico Institute of Mining and Technology, October 2004. 

Qualifies for Air Force CATEX A2.3.27.

The proposed action would employ a 500' x 8" powder gun to propel at supersonic 

speeds, 24" x 8" canisters containing approximately 18 kg of thickened TBP. The 

experiment entailed three methods of TBP dispersal, with a preliminary test matrix of 

fourteen shots. 

Reference: REC Kinetic Energy Interceptor Program – Stage-1 Rocket Motor 

Manufacture and Static Fire Tests at Alliant Tech Launch Systems (ATK) Clearfield 

Facility, Utah, July 2006. Qualifies for Army CATEX (h)(5).

ATK would manufacture and static fire test up to five KEI Stage-1 rocket motors at its 

existing contractor facilities in Utah.

Reference: REC Kinetic Energy Interceptor Program – Stage-2 Rocket Motor 

Manufacture and Static Fire Tests at the Alliant Techsystems, Inc. (ATK) Elkton 

Facility, Maryland, November, 2006. Qualifies for Army CATEX (h)(5).

ATK would manufacture and static fire test up to four KEI Stage-2 rocket motors at its 

existing contractor facilities in Maryland.

Reference: REC Radiation Testing of Microsatellite Components, May 2007. 

Qualifies for Air Force CATEX A2.3.27.

Proton testing of COTS microsatellite components used by MDA's DSE program would

be conducted at the Indiana University Cyclotron Facility in Bloomington, Indiana to 

evaluate the performance of COTS components under a space radiation environment. 

During testing, each component will be irradiated with 200 MeV protons and monitored 

to identify the sensitivity of microsatellite components to radiation at levels that simulate 

the environment in space. A total of four tests were planned.

Reference: MFR Kinetic Energy Interceptor Motor Disposition, September 2010. 

Qualifies for Navy CATEX (f)(17).

It was determined the proposed action was already covered by NEPA consideration in 

RECs for the Stage-1 Rocket Motor Manufacture and Static Fire Tests at ATK Clearfield 

Facility, Utah, July 2006 and the Stage-2 Rocket Motor Manufacture and Static Fire 

Tests at the ATK Elkton Facility, Maryland, November, 2006. The proposed action

under this MFR was to static fire two Stage 1 motors and two Stage 2 motors at ATK 

Promontory, UT. The third Stage 1 motor would be transported to Eglin AFB, FL or 

Redstone Arsenal, AL and used to conduct insensitive munitions testing.

137 October 2013
Reference: RCE Construction of a Deckhouse Support Building, Relocatable 

Deckhouse, Installation and Checkout of an Aegis Ashore Weapons System at 

Lockheed Martin Mission Systems and Sensors (MS2), Moorestown, New Jersey, May 

2011. Qualifies for Navy CATEX (f)(17).

The proposed action among other things is to test, check out and ensure the Aegis Ashore 

system is operationally ready. Testing of the AA system would be similar to existing 

testing protocols MS2 uses for Aegis Weapons Systems.

138 October 2013
Table B-20.1 Comparative Analysis of MDA CATEX B-20to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard

Notes

Applicable 

CATEXs B-20 (h)(5) (f)(17) A2.3.27 (28)

Characteristics 

of the Action

Research, testing, and operations conducted 

at existing facilities and plants or 

laboratories (including contractor-operated 

laboratories and plants) and in compliance 

with all applicable safety, environmental 

and natural conservation laws. 

Proposed action is limited to research, 

testing, and operations conducted at existing 

enclosed facilities consistent with 

previously established safety levels and in 

compliance with applicable federal, state, 

and local standards. For facilities without 

existing NEPA analysis, including 

contractor-operated facilities, if the 

operation will substantially increase the 

extent of potential environmental impacts or 

is controversial, an EA (and possibly an 

EIS) is required.

MDA has extensive experience working at 

U.S. Army installations such as the Ronald 

Reagan Test Site, USAKA; WSMR, NM; 

Redstone Arsenal, AL; Fort Greely, AK; 

Fort Drum, NY; and Fort Belvoir, VA.

Proposed action is limited to new activities 

conducted at established laboratories and 

plants (including contractor-operated 

laboratories and plants) where all airborne 

emissions, waterborne effluent, external 

ionizing and non-ionizing radiation levels, 

outdoor noise, and solid and bulk waste 

disposal practices are in compliance with 

existing applicable Federal, state, and local 

laws and regulations. 

MDA has extensive experience working at 

U.S. Navy installations such as PMRF, HI; 

Point Mugu Sea Range, CA; San Nicolas 

Island, CA; and Dahlgren Naval Base, VA.

Proposed action is limited to normal or 

routine basic and applied scientific research 

confined to the laboratory and in 

compliance with all applicable safety, 

environmental, and natural resource 

conservation laws. 

MDA has extensive experience working at 

U.S. Air Force Installations such as 

Vandenberg AFB, CA; Edwards AFB, CA; 

Wake Island; Clear AFS, AK; Elmendorf 

AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

Proposed action is limited to contracts for 

activities conducted at established 

laboratories and facilities, to include 

contractor-operated laboratories and 

facilities on USCG-owned property where 

all airborne emissions, waterborne effluents, 

external radiation levels, outdoor noise, and 

solid and bulk waste disposal practices are 

in compliance with existing applicable 

Federal, state, and local laws and 

regulations. (Checklist required.) 

Examples of these types of activities 

include research, testing, and operation of 

sensors (radars) and their components, 

lasers, propellants, missile payloads, 

communication equipment, integrated 

missile defense systems, and simulated high 

altitude component and material testing.

Methods of 

Implementing 

the Action

Work with host installation or contractor 

owned lab to identify applicable laws, 

regulations, management plans and SOPs.

Work with host installation or contractor 

owned lab to obtain require permits and to 

record and report usage and disposal of any 

test items or materials.

Work with host installation or contractor 

owned lab to either review existing NEPA 

and/or prepare necessary NEPA 

documentation.

Work with host installation or contractor 

owned lab to conduct any required 

coordination with Federal and state 

agencies.

Installation staff to identify applicable laws, 

regulations, management plans and SOPs or 

assist contractor owned lab in same.

Installation staff to obtain require permits 

and to record and report usage and disposal 

of any test items or materials or assist 

contractor owned lab in same.

Installation staff to review existing NEPA 

and/or prepare necessary NEPA 

documentation or assist contractor owned 

lab in same.

Installation staff to conduct any required 

coordination with Federal and state agencies 

or assist contractor owned lab in same.

Same Same Similar Because MDA owns no facilities of this 

type, these activities are conducted either at 

existing military facilities or at government 

defense contractor owned facilities. These 

facilities already have established and longstanding environmental programs in place 

governing air emissions, wastewater and 

storm water discharges, solid and hazardous 

waste storage and disposal, natural and 

cultural resource protection, as well as strict 

procedures to protect workers and the 

general public from ionizing and nonionizing radiation.

Frequency of the 

Actions

These types of activities are conducted 

much less frequently at MDA than with the 

Military Services and Government 

contractors. This is because these facilities 

are already exclusively dedicated to these 

activities on a day-to-day, year round basis. 

MDA, as a visitor, conducts its activities at 

these facilities much less frequently.

Greater Greater Greater Unknown Typical laboratory operations subject to 

conditions of regulatory permits and 

management plans.

Applicable 

Regulations

NEPA, CERCLA, CWA, CAA and other 

applicable Federal and state regulations, 

DoD and Military Service requirements, 

and industry standards.

Same Same Same Same

Applicable SOPs Plant or laboratory specific, but are 

consistent among similar test facilities.

Same Same Same Same

139 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force U.S. Coast Guard Notes

Timing and 

Context

Because MDA has no real property or test 

facilities, it must conduct these activities on 

host facilities. They can occur at any time.

Continuous over time at high levels relative 

to MDA.

Continuous over time at high levels relative 

to MDA.

Continuous over time at high levels relative 

to MDA.

Unknown

Extraordinary 

Circumstances

None Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of testing, MDA knows of 

no known significant impacts from these 

types of activities. 

Same Same Same Same

140 October 2013
Table B-20.2 Comparative Analysis of MDA Proposed CATEX B-20 to MDA Environmental Analyses.

Benchmarking 

Categories MDA Final Programmatic Environmental Assessment of 

Propulsion Testing Capabilities at the Phillips 

Laboratory, Edwards Air Force Base, California, 

January 1998, FONSI Signed

Construction of a High Altitude Simulation 

Chamber and Conduct of MDA Lethality 

Tests at Porton Down, UK, EO 12114 

Environmental Review, October 2002

Vertical Gun Test Environmental Assessment, 

May 2004, FONSI Signed

Missile Defense Agency MUDPACK II Test 

Environmental Assessment, April 2005, 

FONSI Signed Applicable 

CATEXs B-20

Characteristics 

of the Action

Research, testing, and operations conducted at existing 

facilities and plants or laboratories (including 

contractor-operated laboratories and plants) and in 

compliance with all applicable safety, environmental 

and natural conservation laws. 

Phillips Laboratory at Edwards AFB, California 

proposes to increase propellant testing operations;

conduct of rocket propulsion basic exploratory and 

developmental research; execute the research, and 

exploratory development and advanced development 

programs for interdisciplinary space technology and 

rocket programs; provide support and capability for 

other governmental agencies and private industries to 

conduct contracted and in-house research and 

development; and ensure compliance with applicable 

environmental laws and regulation.

The proposed action is construction of a steel linear 

chamber/tube approximately 425 ft long with vacuum 

pumps and supporting infrastructure to simulate a high 

altitude environment for testing the dispersal of 

chemical agents released from high altitude (up to 100 

km) ballistic missile intercepts. This vacuum chamber 

will serve as an experimental laboratory to conduct 

approximately 100 dispersion tests over four years. 

MDA would conduct up to six vertical gun tests within 

a two-week period at the NMT 3K North site. 

Canisters containing TBP would be launched at the 3K 

North site. The canisters would contain approximately 

110 pounds of TBP thickened using polybutyl 

methacrylate enhanced with blue dye for observation 

purposes. A small amount of explosives would be 

used to rupture the canister tanks during ascent at an 

altitude of approximately 1,640 feet, resulting in the 

creation of a short-lived aerosol debris cloud and the 

subsequent dispersion of TBP droplets. 

MDA would complete rest activities at the HELST), 

located at the WSMR in New Mexico. 

Methods of 

Implementing 

the Action

Work with host installation or contractor owned lab to 

identify applicable laws, regulations, management 

plans and SOPs.

Work with host installation or contractor owned lab to 

obtain require permits and to record and report usage 

and disposal of any test items or materials.

Work with host installation or contractor owned lab to 

either review existing NEPA and/or prepare necessary 

NEPA documentation.

Work with host installation or contractor owned lab to 

conduct any required coordination with Federal and 

state agencies.

Same Same Same Same

Frequency of the 

Actions

These types of activities are conducted much less 

frequently at MDA than with the Military Services and

Government contractors. This is because these 

facilities are already exclusively dedicated to these 

activities on a day-to-day, year round basis. MDA, as a 

visitor, conducts its activities at these facilities much 

less frequently.

An incremental increase in existing testing which is 

already frequent and continuous over time.

100 dispersion tests over 4 years. Multiple tests during summer months within a twoweek period. Incremental increase in existing tests that 

occur frequently over time.

A series of tests over a short period of time.

Applicable 

Regulations

NEPA, CERCLA, CWA, CAA and other applicable 

Federal and state regulations, DoD and Service 

requirements, and industry standards.

Same Follow Host Nation requirements Same Same

Applicable SOPs Plant or laboratory specific, but are consistent among 

similar test facilities.

Same Same Same Same

Timing and 

Context

Because MDA has no real property or test facilities, it 

must conduct these activities on host facilities. They 

can occur at any time.

Same Same Same Same

Extraordinary 

Circumstances

None Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of testing, MDA knows of no known 

significant impacts from these types of operations. 

No adverse environmental impacts have been observed 

at from MDA tests.

No adverse environmental impacts were observed at 

the site from MDA tests.

No adverse environmental impacts were observed at 

the site from MDA tests.

No adverse environmental impacts have occurred at 

HELSTF from MDA tests.

141 October 2013
B-21. Routine installation and use of radars, telemetry systems, communications 

equipment, and other essentially similar facilities and equipment within a launch 

facility, mobile platform, military installation, training area, or previously disturbed 

area that conform to current American National Standards Institute/Institute of 

Electrical and Electronics Engineers (ANSI/IEEE) guidelines for maximum permissible 

exposure to electromagnetic fields. (REC required).

Routine installation and use of radars, telemetry systems, communications equipment, and other 

essentially similar facilities and equipment contemplated by this CATEX are limited to those 

being installed at a launch facility, mobile platform, military installation, training area, or 

previously disturbed areas and conforms to current ANSI/IEEE guidelines for maximum 

permissible exposure to electromagnetic fields. By confining placement of facilities and 

equipment to previously disturbed areas and existing developed operational areas, we are 

minimizing the potential impact to sensitive environments, biological and cultural resources (i.e., 

less likely impact cultural or biological resource if the area was either on paved or otherwise 

developed land or already disturbed (cleared and excavated at some point in the past)). Protected 

biological and cultural resources at these facilities and installations have already been identified

by installation personnel. ANSI/IEE guidelines ensure there are no impacts to the environment 

or humans from exposure to electromagnetic fields. Also, temporary exposure of birds flying 

through the radar beam has been extensively studied in MDA EAs and EISs and has been found 

not to be significant.

The installation and use of radars, telemetry systems, communications equipment, and other 

essentially similar facilities and equipment contemplated by this CATEX would typically rely on 

the infrastructure and surrounding environment where similar activities are already being 

conducted by the Services and other agencies (e.g., the use of range radars, telemetry collection 

devices, communication equipments, re-radiation towers, etc.). There would not be an increase 

in frequency of this activity due to use of this CATEX as MDA has been conducting these 

activities on host installation/ranges for several years complying with the NEPA regulations of 

the respective Service. No difference exists in the operation of MDA facilities and those of the 

Services in terms of time or day of use, frequency, or physical and biological effects of radar 

emissions. MDA would follow the same regulations, directives, protocols and procedures as the 

Services. 

The routine installation and use of radars, telemetry systems, communications equipment, and 

other similar facilities and equipment typically involves minor site preparation (especially if an 

existing radar hardstand is unavailable for use), transport, set up, calibration, and operation. 

Typical site improvements might include one or more of the following activities:

• Site clearing and grubbing (<5 acres, previously disturbed area);

• Minor trenching and connection to existing power sources;

• Grading, filling, and compaction of hardstand area (<1 acre, previously disturbed area);

• Installation of satellite dishes for communications;

• Installation of temporary lighting;

• Installation of grounding and lightning protection poles;

142 October 2013
• Installation of temporary fencing;

• Installation of noise attenuation barriers (if needed);

• Trimming and/or topping of trees in front of radar face;

• Construction of a gravel parking lot for up to 15 vehicles; and

• Construction of a gravel access road.

The radar, telemetry systems, communications equipment, and other similar facilities and 

equipment would be located and operated to minimize disruption to the on-going activities at the 

existing site. Electric power would be provided to the site by the installation or local utility in 

accordance with state approved procedures and Federal/state requirements. Additional lines and 

poles may be required to be installed within existing right-of-ways and previously disturbed 

areas. Alternatively, power could be provided by diesel generators, along with small backup 

generators for emergency use, and all would be periodically operated according to maintenance 

schedules and any permit restrictions. Safety from electromagnetic radiation would be assured 

by requiring compliance with current ANSI/IEEE guidelines for maximum permissible exposure 

to electromagnetic fields using keep out areas and fencing.

These activities would be conducted following existing installation SOPs, as well as all 

applicable Federal, state and DoD regulations designed to protect the quality of the human 

environment. 

As long as the activities contemplated by this CATEX are conducted at a launch facility, mobile 

platform, military installation, training area, or previously disturbed area in conformance with 

current ANSI/IEEE guidelines for maximum permissible exposure to electromagnetic fields;

follow existing installation SOPs; and comply with Federal, state, local and tribal environmental 

requirements; they would not have the potential to create significant environmental impacts. It is 

important to note that MDA has been conducting such activities at host installations/ranges under 

the applicable host Service NEPA Regulations and CATEXs for over 20 years. Through MDA’s 

experience as well as experience by the Services, no adverse environmental or human health 

impacts have been observed from these activities.

The Team reviewed other agencies’ CATEXs, particularly the Military Services where MDA 

typically conducts mission activities on their ranges/installations. The Team determined the 

above-enumerated CATEX encompassed activities routinely conducted in restricted areas at a 

launch facility, mobile platform, military installation, training area or previously disturbed areas

because these activities: 

1) Are the same type of activities conducted by our host installations and ranges at the same 

locations;

2) Must meet current ANSI/IEEE guidelines for maximum permissible exposure to 

electromagnetic fields;

3) Follow existing installation standard operating procedures; and

4) Must meet Federal, state, local and tribal environmental requirements. 

143 October 2013
The activities contemplated by this CATEX do not have an individual or cumulative significant 

impact on the environment. This CATEX is supported by environmental reviews and 

administrative records from MDA projects.

MDA also reviewed the impact analyses and conclusions in previously prepared programmatic 

and site-specific NEPA documentation, specifically for the routine installation and use of radars, 

telemetry systems, communications equipment, and other essentially similar facilities and 

equipment. These activities have been analyzed in a number of previously prepared documents, 

including the Pacific Missile Range Facility Intercept Test Support Environmental 

Assessment/Overseas Environmental Assessment (Navy 2010); Missile Defense Agency Ballistic 

Missile Defense System (BMDS) Programmatic Environmental Impact Statement (MDA 2007); 

Ballistic Missile Defense Programmatic Environmental Impact Statement (BMDO, 1994); 

Ground-Based Midcourse Defense Initial Defense Operations Capability at Vandenberg Air 

Force Base Environmental Assessment (MDA, 2003); Ground-Based Midcourse Defense 

Extended Test Range Environmental Impact Statement (U.S. Army Space and Missile Defense 

Command, 2003); Ground-Based Midcourse Defense (GMD) Validation of Operations Concept 

(VOC) Supplemental Environmental Assessment (MDA 2002); Validation of Operations Concept 

(VOC) Environmental Assessment (MDA 2002); National Missile Defense Deployment 

Environmental Impact Statement (U.S. Army Space and Missile Defense Command, 2000); 

Theater Missile Defense Extended Test Range Supplemental Environmental Impact Statement 

(U.S. Army Space and Strategic Defense Command, 1998a); Theater Missile Defense Extended 

Test Range Environmental Impact Statement (U.S. Army Space and Strategic Defense 

Command, 1994a); Evolved Expendable Launch Vehicle Program Environmental Impact 

Statement (U.S. Department of the Air Force, 1998); Point Mugu Environmental Impact 

Statement/Overseas Environmental Impact Statement (U.S. Department of the Navy, 2002b); and 

Pacific Missile Range Facility Enhanced Capability Environmental Impact Statement (U.S. 

Department of the Navy, 1998), and Mobile Sensors Environmental Assessment (MDA, 2005). 

A sample of these reviews is summarized in the next section.

These previous analyses, along with more than 20 years of Agency experience, show that 

potential impacts from routine installation and use of radars, telemetry systems, communications 

equipment, and other essentially similar facilities and equipment, including construction-related 

impacts would be short-term and insignificant. Activities that would continue at a launch 

facility, mobile platform, military installation, training area or previously disturbed area would 

not result in any significant impacts.

All activities would meet current ANSI/IEEE guidelines for maximum permissible exposure to 

electromagnetic fields and follow applicable regulations and established guidelines and 

management practices. Previous analyses show the impacts of such activities in support of 

MDA’s BMDS would not be significant because such activities would be performed in 

accordance with existing regulations.

To ensure only those actions having negligible impacts on the human environment are 

contemplated by this CATEX, the Team proposed a REC be prepared to document the 

determination whether the action is either appropriately categorically excluded or whether it 

requires further analysis with an EA or EIS.

144 October 2013
The limiting provisions were established to both conform to the evidence presented in the 

administrative record to clarify meaning of those limiting provisions found in the administrative 

record, or to add to or modify limitations found in the record based on MDA experience to 

further avoid the potential for significant impacts to the human environment.

As documented in Table B-21.1 and B-21.2, the Team conducted a comparative analysis (or 

benchmarking) of MDA’s proposed CATEX to other applicable government organizations’ 

CATEXs. We compared the characteristics of the action, methods of implementing the action, 

frequency of the action, applicable regulations, applicable SOPs, timing and context, 

extraordinary circumstances, and known impacts from the proposed action. The Team 

determined that: 

1) An extensive history of the application of similar CATEXs by the Services and other Federal 

agencies exists; 

2) MDA, as a DoD component, conducts these types of activities in a similar manner and 

frequency as the Services and other Federal agencies; 

3) MDA, the Services, and other Federal agencies, with very few exceptions, must meet the 

same requirements to protect the environment and employ similar standard operating 

procedures to ensure compliance; 

4) Extraordinary circumstances associated with its application are absent and documented by a 

REC; and 

5) No known significant impacts are associated with this proposed activity, beyond those 

resulting from accidental fuel spills during fueling activities, which are unplanned actions. 

Potential impacts are mitigated using spill containment equipment and SOPs. 

Therefore, the Team determined this CATEX is applicable to MDA projects and that the 

Services’ and other Federal agencies’ actions were similar in nature, scope, and impact on the 

human environment as those performed by MDA. 

Comparable Agency Categorical Exclusion and Administrative Record 

U.S. Army 

Reference: 32 CFR Part 651, Appendix B, Categorical Exclusions

(e)(2) Acquisition, installation, and operation of utility and communication systems, 

mobile antennas, data processing cable and similar electronic equipment that use existing 

right-of-way, easement, distribution systems, and/or facilities (REC required). 

U.S. Navy

Reference: OPNAVINST 5090.1C Categorical Exclusions

(f) (36) Acquisition, installation, and operation of utility (e.g., water, sewer, electrical) 

and communication systems (e.g., data processing cable and similar electronic 

equipment) which use existing rights of way, easements, distribution systems, and/or 

facilities.

145 October 2013
(f)(44) Routine testing and evaluation of military equipment on a military reservation or 

an established range, restricted area, or operating area; similar in type, intensity and 

setting, including physical location and time of year, to other actions for which it has 

been determined, through NEPA analysis where the Department of Navy (DON) was a 

lead or cooperating agency, that there were no significant impacts; and conducted in 

accordance with all applicable standard operating procedures protective of the 

environment.

U.S. Air Force 

Reference: 32 CFR Part 989, Appendix B, Categorical Exclusions

A2.3.12. Installing, operating, modifying, and routinely repairing and replacing utility 

and communications systems, data processing cable, and similar electronic equipment 

that use existing rights of way, easements, distribution systems, or facilities. 

A2.3.13. Installing or modifying airfield operational equipment (such as runway visual 

range equipment, visual glide path systems, and remote transmitter or receiver facilities) 

on airfield property and usually accessible only to maintenance personnel. 

A2.3.14. Installing on previously developed land, equipment that does not substantially 

alter land use (i.e., land use of more than one acre). This includes outgrants to private 

lessees for similar construction. The EPF must document application of this CATEX on 

AF Form 813. 

Missile Defense Agency Environmental Reviews

Reference: Theater High Altitude Area Defense (THAAD) Pacific Test Flights 

Environmental Assessment, December 2002, resulting in a FONSI

This EA analyzed the proposed use of an upgraded version of the THAAD Prototype 

Radar. There would be a maximum of two radars on location during flight testing. Only 

one radar would be operated at any given time. The other radar would be stored in an 

existing area of the installation and would be available for use should problems be 

encountered with the primary radar. An electromagnetic radiation hazard exclusion area 

would be established in front and to the side of the THAAD radar antenna. The 

electromagnetic radiation hazard exclusion area for personnel would extend for 1,312 feet 

in front and to the side of the radar.

Thirteen broad areas of environmental consideration were considered for assessing

potential impacts. MDA determined no significant impacts would occur as a result of the 

construction and operation of any of the THAAD test sites and related support facilities. 

Over the course of six years, MDA has conducted over six THAAD tests at PMRF with 

no environmental impacts observed from the siting and operation of THAAD radars 

during tests by MDA.

146 October 2013
Reference: Ground-Based Midcourse Defense (GMD) Extended Test Range (ETR) 

Environmental Impact Statement, July 2003

The proposed action, among other things, was to site, install/construct and operate 

various radars, telemetry systems, communications equipment, and other essentially 

similar facilities and equipment at additional launch and test facilities at various 

locations, including the SBX in the Pacific Region, to support more realistic interceptor 

flight tests. Most tests would include the launch of a target missile; tracking by range and 

other land-based, sea-based, airborne, and space-based sensors; launch of an interceptor

missile; target intercept; and debris impacting into broad open areas of the Pacific Ocean. 

Each alternative would include common GMD test components consisting of GBIs, target 

missiles, an IDT, the SBX, and other sensors and instrumentation.

No significant environmental impacts or cumulative impacts on resource areas addressed

for any activity considered in implementing the proposed action were found in this 

analysis. As appropriate, mitigation measures would be developed to address any sitespecific significant impacts. MDA has conducted at least four tests per year at locations 

around the world using mobile radars, telemetry and communication equipment as part of 

the tests with no reported or observed environmental impacts.

Reference: Missile Defense Agency Mobile Launch Platform (MLP) Environmental

Assessment, June 2004, resulting in a FONSI

This EA analyzed, among other things, providing a mobile sea-based platform from

which to more realistically test sensors (radars, telemetry, and optical systems) in support 

of MDA’s mission. The MLP would also provide MDA the capability to use sensors at 

test support positions in remote areas of the ocean by locating these sensors on the MLP.

The MLP is the former USS Tripoli (LPH 10), a converted U.S. Navy Iwo Jima Class 

Amphibious Assault Ship (Helicopter). The sensors that would be tested from the MLP 

include radar, telemetry, and optical systems. Examples of radars to be used include: 

TPS-X, Mk-74, and Coherent Signal Processor radars that already exist, and the BMDS 

radar, being developed by the MDA. Telemetry systems could include the Transportable 

Telemetry System and mobile range safety systems. Mobile optical systems such as the 

Stabilized High-Accuracy Optical Tracking System could also be placed on the MLP. 

Additional sensor systems may be temporarily based on the MLP as required. 

After analyzing the proposed action, no significant short-term or long-term effects to

the environment or surrounding populations are expected. The MLP has been used on 

average two to five missions per year since 2005 with no adverse environmental impacts 

being reported or observed.

147 October 2013
Reference: Mobile Sensors Environmental Assessment, September 2005, resulting in 

a FONSI

MDA proposes to use land-based mobile sensors (i.e., radar, telemetry and

communication, command and control, and optical systems) and airborne sensor systems

(i.e., optical and infrared systems). A test event may use any combination of mobile 

land-based and one of the airborne mobile sensors. The land-based mobile sensors would 

be transportable systems that could operate as autonomous systems or as part of an 

integrated sensor system. Airborne systems also could operate as autonomous systems, 

but typically would be part of an integrated sensor system.

Land-based mobile sensors considered as part of the proposed action include Radar: TPSX, FBX-T, MK-74 Target Tracking Illuminating System Radar, and MPS-36 Radar; 

Telemetry: TTS, MRSS, and; TRACS; Optical Systems: SHOTS and ISTEF.

There are three types of activities associated with using these land-based mobile sensors,

pre-operational, operational, and post-operational activities. Pre-operational activities 

include transporting the sensor, site preparation activities, and checking out sensors; 

operational activities include activating the sensor; and post-operational activities include 

disassembling the sensor and transporting the sensor back to the storage or bed down

location.

Land-based mobile sensors could be sited at the following locations: Vandenberg AFB, 

California; Naval Base Ventura County Port Hueneme/San Nicolas Island/Point Mugu, 

California; PMRF, Hawaii; Niihau, Hawaii; USAKA/Ronald Reagan Ballistic Missile 

Defense Test Site, Republic of the Marshall Islands; Midway Island; Wake Island; 

WSMR, New Mexico; Eareckson AFS, Alaska; King Salmon Air Station, Alaska; 

Kodiak Launch Complex, Alaska; Merle K. Smith Airport, Cordova, Alaska; Naval Air 

Station Whidbey Island, Washington; and National Aeronautics and Space 

Administration Wallops Island, Virginia.

The proposed airborne sensor systems include the HALO-I, HALO-II, and the WASP. 

Activities associated with airborne sensor systems include flying airborne sensor systems

to test support locations; setting up, checking out and performing maintenance on aircraft 

and airborne sensor systems at the staging and bed down locations; calibration of sensors; 

activation of sensors; flying airborne sensor systems from staging locations and test 

support locations back to bed down locations; ensuring safety of personnel operating the 

sensors; and waste disposal. Operations for airborne sensor systems would include

activities at the bed down, staging, and test locations.

Bed down locations of airborne sensors could include: Jones Riverside Airport in Tulsa, 

Oklahoma; Majors Army Air Field in Greenville, Texas; Edwards AFB, California; and 

Kirtland AFB, New Mexico. 

148 October 2013
Staging Locations of airborne sensors could include: Adak, Alaska; Majuro Island, RMI; 

Anchorage International Airport, Alaska; McCarran International Airport, Nevada; 

Anderson AFB, Guam; McChord AFB, Washington; Andrews AFB, Maryland; 

Melbourne International Airport, Florida; Edwards AFB, California; Midway Island; 

Eglin AFB, Florida; Monterey Airport, California; Elmendorf AFB, Alaska; Nellis AFB, 

Nevada; MacDill AFB, Florida; Palm Beach International Airport, Florida; Majors Army 

Air Field, Texas; Palm Springs International Airport, California; Harlingen Airport, 

Texas; PMRF, Hawaii; Hickam AFB, Hawaii; Patrick AFB, Florida; Holloman AFB, 

New Mexico; Point Mugu, California; Huntsville International Airport, Alabama; Jones 

Riverside Airport, Oklahoma; Johnston Atoll; San Jose International Airport, California; 

Kodiak Airport, Alaska; Seattle Tacoma International Airport, Washington; Lihue 

International Airport, Hawaii; Travis AFB, California; Kaneohe Bay Marine Corp Air 

Station, Hawaii; Tulsa International Airport, Oklahoma; Keesler AFB, Mississippi; 

Tyndall AFB, Florida; Key West NAS, Florida; USAKA/RTS, RMI; Kirtland AFB, New 

Mexico; Wallops Island (NASA), Virginia; and Wake Island. 

Test locations of airborne sensors could include: airspace over BOA airspace over land 

portions of ranges (WSMR, New Mexico or Holloman AFB, New Mexico); and airspace 

over ocean portion of ranges (Eastern Test Range, Patrick AFB, Florida; San Nicolas 

Island, California; PMRF, Hawaii; Western Range, Vandenberg AFB, California; or 

USAKA/RTS). 

The proposed action, with electromagnetic radiation/electromagnetic interference surveys

incorporated as part of the proposed action, would not have a significant adverse effect 

on the environment.

MDA has since conducted numerous test activities using numerous radars, telemetry and 

communication systems at many of the sites listed in the EA with no adverse 

environmental impacts being reported or observed.

Reference: Missile Defense Agency Ground-Based Midcourse Defense (GMD) SeaBased X-Band (SBX) Radar Placement and Operation Adak, Alaska, October 2005, 

resulting in a FONSI

This EA analyzed among other things, operation of the SBX Radar while at the Primary 

Support Base (PSB) and the use of onshore PSB assets and infrastructure to support SBX 

operations. 

Thirteen areas of environmental consideration were evaluated and based on analysis of 

the proposed placement and operation the SBX at the PSB but would not be limited to 

Adak Island, Alaska; no significant impacts affecting the quality of the human 

environment were identified. Due to program changes, the SBX continues to operate for 

tests, but has been relocated to another site.

149 October 2013
Reference: Missile Defense Agency Ballistic Missile Defense System (BMDS) 

Programmatic Environmental Impact Statement, January 2007

This PEIS analyzed among other things the development or enhancement of BMDS 

sensors to acquire, record, and process data on threat missiles and interceptor missiles; 

detect and track threat missiles; direct interceptor missiles or other defenses (e.g., lasers); 

and assess whether a threat missile has been destroyed. 

The operating environments of the existing and proposed BMDS sensors can be 

considered in four general categories. Land-based sensors may be fixed, located in or on 

a building, or mobile, located on a vehicle or trailer. Air-based sensors are located on 

platforms that can travel through the air such as airplanes, balloons, and airships. Seabased sensors are located on platforms that travel on water (e.g., ships or a floating 

platform) or are fixed in water (e.g., a man-made island or platform like an oil platform 

that is fixed to the seafloor). Space-based sensors are located on satellites, which travel 

in circular or elliptical orbits around the Earth. 

The affected environment includes all land, air, water, and atmospheric environments 

where proposed activities are reasonably foreseeable. For this PEIS, the affected 

environment includes all locations, ranges, installations, and facilities that MDA has 

used, uses, or proposes to use for the BMDS both within and outside the U.S.

No significant environmental impacts or cumulative impacts on resource areas addressed 

for any activity considered in implementing the BMDS were found in this programmatic 

impact analysis. MDA also analyzed the potential impacts of electromagnetic radiation 

on wildlife and determined that there would be no significant impact. Although, there 

could be impacts associated with the specific BMDS program activities at specific 

locations; they would be addressed, as appropriate, in subsequent NEPA analyses that 

would tier from the PEIS. As appropriate, mitigation measures would be developed to 

address any site-specific significant impacts. MDA has conducted at least four tests 

every year at locations around the world using mobile radars, telemetry and 

communication equipment as part of the tests with no reported or observed environmental 

impacts.

Reference: Missile Defense Agency Relocatable In-Flight Interceptor 

Communications System Data Terminal #2 at Vandenberg Air Force Base, 

Supplemental Environmental Assessment, November 2007, resulting in a FONSI

This SEA analyzed in part the siting, construction and operation of a second RIDT, at a 

site adjacent to the existing RIDT along El Rancho Road on Vandenberg AFB. 

An IDT is a Super High Frequency radio transmitter and receiver that provide

communications between the GFC Components and the GBI. Calibration may occur 

approximately twice per year. An RIDT is made up by the integration of the compound, 

facilities, antenna, communications node equipment, long haul communications, and 

embedded test and training capability. Long haul communications are communications 

150 October 2013
lines which connect the RIDT site to the larger (off-base) GMD communications 

network. Embedded test capability refers to the equipment installed at the RIDT facility, 

which allows GMD to run tests and simulations, and gather flight test data for analysis.

The Vandenberg AFB IDTs are designed to be relocatable, to provide the flexibility to 

remove, replace, and relocate the terminal quickly should the need arise.

Based on analysis of the proposed construction and operation of a second RIDT at 

Vandenberg AFB, this SEA identified no significant impacts affecting the quality of the 

human environment. No environmental impacts have been reported or observed since the 

construction and operation of the IDT#2 at VAFB.

Reference: AF 813 TPS-X Radar Deployment/Use, September, 2002. Qualifies for 

Air Force CATEX A2.3.14.

The proposed action included the deployment and use of the TPS-X Radar on a 

temporary basis on previously disturbed land. No major construction would be required, 

but the proposed action would include installation of a perimeter fence, installation of 

support utilities and operation of portable generators if commercial power were not 

available.

Reference: AF 813 Temporary Use of Transportable Telemetry Equipment at 

Eareckson AFS in support of Flight Test 04-5, August 2005. Qualifies for Air Force 

CATEX A.2.3.12 andA2.3.14.

The proposed action was to temporarily install a communications system on previously 

disturbed land with no permanent alteration of the site. Installation would include two 

transportable telemetry dishes and van; one telemetry van and one storage van; two 

SATCOM trailers with antennae; two 60 kW diesel electric generators with doublewalled fuel tanks; and two connex trailers to support FT-4-5 mission.

Reference: REC AN/TPY-2 Radar Deployment at the Ted Stevens Marine Research 

Institute (TSMRI) on the National Oceanic and Atmospheric Administration (NOAA) 

Site in Juneau, Alaska in Support of Flight Test Ground-Based Interceptor (FTG) -04, 

May 2007. Qualifies for Army CATEX (E)(2).

The proposed action was to site, transport, set up, calibrate, and operate the AN/TPY-2 

radar at TSMRI. The AN/TPY-2 radar and system components typically require 

approximately 3 acres of graded compacted hardstand surface and approximately 12 

acres of clear zone to allow unobstructed, low-elevation radiation.

Reference: AF 813 Ballistic Missile Defense System Communications Support 

Complex – Transportable (BCSC-T), February 2008. Qualifies for CATEX AF 

A2.3.14.

151 October 2013
The proposed action was to temporarily site a transportable communications package 

consisting of three distinct transportable components (a protected communication control 

system, satellite communication, and power) on previously disturbed land.

Reference: AF 813 MDA/GMD Extended Test Range- VAFB LF-24 Mods for Test, 

August 2008. Qualifies for Air Force CATEX A2.3.14.

The proposed action among other things included the installation of a re-rad tower.

Reference: AF 813 MDA Transportable Telemetry System (TTS) #3 at Kaena Point 

Satellite Tracking Station (KPTS), August 2009. Qualifies for Air Force CATEX 

A2.3.12.

The proposed action was to site the TTS#3 on an existing concrete pad adjacent to the 

HULA B antenna. No new generators and no new fuel storage facilities would be 

required.

Reference: AF 813 AN/TPY-2 Radar Deployment at Wake Island in support of MDA 

Ballistic Missile Defense Systems (BMDS) Flight Tests, November 2009. Qualifies for 

Air Force CATEX A2.3.14.

The proposed action was to site, set up, calibrate and operate the AN/TPY-2 Radar, 

Defense Satellite Communication System, Transportable Telemetry System and 

supporting communications equipment on previously disturbed land on Wake Island. 

Minor site clearing and preparation would occur and all cabling would either use existing 

buried conduit or be laid on the ground in protected cable trays.

Reference: AF 813 Beddown of Missile Defense Agency (MDA) Mobile Telemetry 

System at Kaena Point Satellite Tracking Station, December, 2010. Qualifies for Air 

Force CATEX A2.3.12.

The proposed action was to site, transport, set up, calibrate and operate a Mobile 

Telemetry System at Kaena Point Satellite Tracking Station. The MTS requires a 

minimum of 35 x 35 foot space and connection to site power. Existing UPS and backup 

generators would be used. 

Reference: AF 813 Air-borne Infrared Ground-based Operations at Site 460, VAFB, 

June 2011. Qualifies for Air Force CATEX A2.3.12.

MDA would set up and test an ABIR Data Collection system at VAFB Site 460. The 

system consists of: 1) Multispectral Targeting System-B ground-mounted sensor, 2) an 

airborne-capable computer processor enclosed in a secure shelter, and 3) an Operations 

Control Van to support personnel monitoring the data and equipment.

152 October 2013
Table B-21.1 Comparative Analysis of MDA CATEX B-21 to Other Agency CATEXs.

Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force

Notes

Applicable 

CATEXs B-21 (c)(1) and (e)(2) (f)(36) and (44) A2.3.12, A2.3.13, and A2.3.14

Characteristics 

of the Action

Routine installation and use of radars, telemetry 

systems, communications equipment, and other 

essentially similar facilities and equipment within a 

launch facility, mobile platform, military installation, 

training area, or previously disturbed area that conform 

to current ANSI/IEEE guidelines for maximum 

permissible exposure to electromagnetic fields. (REC 

required). 

Limited site preparations (e.g., grading, gravel road 

construction, filling, trenching, etc.) if any), are 

conducted; spill containment barriers are used to contain 

fuel spills and coolant leaks. Temporary fencing, 

lightning protection systems, and lighting would be 

installed per local requirements to minimize “shine.”

Cables can either lie on ground or be in conduit; if site 

conditions and time permits, cabling can be placed in 

shallow trenches dug in previously disturbed areas and 

utility easements.

Diesel fuel provided by installation and conforms to air 

permit and local requirements (e.g., ultra low sulfur 

fuel).

Installation and operation of equipment is confined to 

host installation (or in extremely limited instances, 

private property where similar actions are permitted).

Proposed is limited to acquisition, installation, and 

operation of utility and communication systems, 

mobile antennas, data processing cable and similar 

electronic equipment that use existing right-of-way, 

easement, distribution systems, and/or facilities 

(REC required). 

MDA has extensive experience working at U.S. 

Army installations such as the Ronald Reagan Test 

Site, USAKA; WSMR, NM; Redstone Arsenal, AL; 

Fort Greely, AK; Fort Drum, NY; and Fort Belvoir, 

VA.

Proposed is limited to f) (36) Acquisition, 

installation, and operation of utility (e.g., water, 

sewer, electrical) and communication systems (e.g., 

data processing cable and similar electronic 

equipment) which use existing rights of way, 

easements, distribution systems, and/or facilities.

(f) (44) Routine testing and evaluation of military 

equipment on a military reservation or an 

established range, restricted area, or operating area; 

similar in type, intensity and setting, including 

physical location and time of year, to other actions 

for which it has been determined, through NEPA 

analysis where the DON was a lead or cooperating 

agency, that there are no significant impacts; and 

conducted in accordance with all applicable 

standard operating procedures protective of the 

environment; 

MDA has extensive experience working at U.S. 

Navy installations such as PMRF, HI; Point Mugu 

Sea Range, CA; San Nicolas Island, CA; and 

Dahlgren Naval Base, VA.

Proposed action is limited to A2.3.12. Installing, 

operating, modifying, and routinely repairing and 

replacing utility and communications systems, data 

processing cable, and similar electronic equipment 

that use existing rights of way, easements, 

distribution systems, or facilities. 

A2.3.13. Installing or modifying airfield 

operational equipment (such as runway visual range 

equipment, visual glide path systems, and remote 

transmitter or receiver facilities) on airfield property 

and usually accessible only to maintenance 

personnel. 

A2.3.14. Installing on previously developed land, 

equipment that does not substantially alter land use 

(i.e., land use of more than one acre). This includes 

outgrants to private lessees for similar construction. 

The EPF must document application of this CATEX 

on AF Form 813. 

MDA has extensive experience working at U.S. Air 

Force Installations such as Vandenberg AFB, CA; 

Edwards AFB, CA; Wake Island; Clear AFS, AK; 

Elmendorf AFB, AK; Eareckson AFS, AK; and 

Schriever AFB, CO.

The radar, telemetry systems, communications 

equipment, and other similar facilities and 

equipment would be located and operated to 

minimize disruption to the on-going activities at the 

existing site. Electric power would be provided to 

the site by the installation or local utility in 

accordance with state approved procedures and 

Federal/state requirements (may require additional 

lines and poles to be installed within existing rightof-ways or previously disturbed areas). 

Alternatively, power could be provided by diesel 

generators, along with small backup generators for 

emergency use and all would be periodically 

operated according to maintenance schedules. 

Safety from electromagnetic radiation would be 

assured by requiring compliance with current 

ANSI/IEEE guidelines for maximum permissible 

exposure to electromagnetic fields using keep out 

areas and fencing.

Methods of 

Implementing 

the Action

Obtain test plan and CONOPs from MDA test 

proponent.

Work with host installation or property owner to find 

suitable location and permission to install and operate 

equipment.

Work with host installation to identify applicable laws, 

regulations, and SOPs.

Work with host installation to either review existing 

documentation and/or prepare necessary NEPA 

documentation.

Work with host installation or property owner to 

conduct any required site preparation activities.

Deploy equipment to site, install, test, and operate 

equipment per Test CONOPs. 

Retrograde equipment and restore site to original 

condition (or agreed upon condition – e.g., leaving 

behind grounding grids or sound barriers).

Obtain test plan and CONOPs from Army test 

proponent.

Installation staff to find suitable location and 

permission to install and operate equipment.

Installation staff to identify applicable laws, 

regulations, and SOPs.

Installation staff to either review existing 

documentation and/or prepare necessary NEPA 

documentation.

Installation staff to conduct any required site 

preparation activities.

Deploy equipment to site, install, test, and operate 

equipment per Test CONOPs. 

Retrograde equipment and restore site to original 

condition (or agreed upon condition – e.g., leaving 

behind grounding grids or sound barriers).

Same Same

153 October 2013
Benchmarking 

Categories MDA U.S. Army U.S. Navy U.S. Air Force Notes

Frequency of the 

Actions

Generally one time. However, at larger installations, 

MDA could conduct up to two tests/year at any given 

location.

Same Same Same Typical range operations are subject to conditions of 

installation’s regulatory permits, cultural and natural 

resources management plans, and environmental 

restoration program.

Applicable 

Regulations

NEPA, ESA, NHPA, ARPA, CERCLA, CWA, CAA, 

and other applicable Federal and state regulations, DoD 

and Service requirements, and industry standards.

Same Same Same

Applicable SOPs Installation/Manufacturer specific SOPs and BMPs Same Same Same

Timing and 

Context

Radars and support equipment are used to support 

BMDS test events that could occur any time of the year. 

Equipment, many times, is tactical or operational 

equipment and is in short supply; therefore, it is moved 

to other locations as needed.

BMDS test events are conducted at host installations 

designed to conduct same types of testing. MDA relies 

on installation’s infrastructure and sensors. However, 

some BMDS components being tested are either the 

specific system under test or are brought in to augment 

those operated by the host range/installation. If 

adequate power is available from host installation, MDA 

will use available power. However, some systems 

require their own power. For example, the standalone 

tactical radar systems (e.g., the AN/TPY-2 radar) can 

either use available power or generator power; where as 

a missile interceptor and radar weapon system (e.g., 

THAAD or PAC-3 systems) requires the use of their 

own tactical generators. Other times, for test reliability 

purposes, the system under test will run off of host 

power (or shore power) and use tactical or operational 

generators as backup. 

Similar Similar Similar

Extraordinary 

Circumstances

BMDS test events can be delayed and equipment could 

be left at a test site for a while longer (e.g., several 

months) than anticipated.

Presence of cultural, historical, biological resources or 

contamination.

Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of testing, MDA knows of no known 

significant impacts from these types of activities 

including generator use beyond those resulting from 

accidental spills of fuel during fueling activities. 

Potential impacts are mitigated using spill containment 

equipment and fueling SOPs. Contaminated media is 

removed and treated IAW applicable regulations.

Same Same Same

154 October 2013
Table B-21.2 Comparative Analysis of MDA CATEX B-21 to MDA Environmental Analyses.

Benchmarking 

Categories MDA

Theater High Altitude Area 

Defense (THAAD) Pacific Test 

Flights Environmental 

Assessment, December 2002, 

FONSI Signed

Ground-Based Midcourse 

Defense (GMD) Extended Test 

Range (ETR) Environmental 

Impact Statement, July 2003

Mobile Launch Platform 

(MLP) Environmental 

Assessment, June 2004, FONSI 

Signed

Mobile Sensors Environmental 

Assessment, September 2005, 

FONSI Signed

Missile Defense Agency 

Ground-Based Midcourse 

Defense (GMD) Sea-Based XBand (SBX) Radar Placement 

and Operation Adak, Alaska, 

October 2005, FONSI Signed

Missile Defense Agency Ballistic 

Missile Defense System (BMDS) 

Programmatic Environmental 

Impact Statement, January 

2007

Relocatable In-Flight 

Interceptor Communications 

System Data Terminal (IDT) #2 

at Vandenberg Air Force Base, 

Supplemental Environmental 

Assessment, November 2007, 

FONSI Signed

Applicable 

CATEXs B-21

Characteristics 

of the Action

Routine installation and use of 

radars, telemetry systems, 

communications equipment, and 

other essentially similar facilities 

and equipment within a launch 

facility, mobile platform, military 

installation, training area, or 

previously disturbed area that 

conform to current ANSI/IEEE 

guidelines for maximum 

permissible exposure to 

electromagnetic fields. (REC 

required). 

Limited site preparations (e.g., 

grading, gravel road construction, 

filling, trenching, etc.) if any), are 

conducted; spill containment 

barriers are used to contain fuel 

spills and coolant leaks. 

Temporary fencing, lightning 

protection systems, and lighting 

would be installed per local 

requirements to minimize 

“shine.”

Cables can either lie on ground or 

be in conduit; if site conditions 

and time permits, cabling can be 

placed in shallow trenches dug in 

previously disturbed areas and 

utility easements.

Diesel fuel provided by 

installation and conforms to air 

permit and local requirements 

(e.g., ultra low sulfur fuel).

Installation and operation of 

equipment is confined to host 

installation (or in extremely 

limited instances, private property 

where similar actions are 

permitted).

The proposed action was to use 

an upgraded version of the 

THAAD Prototype Radar. The 

radar system consists of four 

individual units: (1) Antenna 

Equipment Unit, (2) Electronic 

Equipment Unit, (3) Cooling 

Equipment Unit, and (4) Prime 

Power Unit. There would be a 

maximum of two radars on 

location during flight testing. 

Only one radar would be operated 

at any given time. An 

electromagnetic radiation hazard 

exclusion area would be 

established in front and to the 

side of the THAAD radar 

antenna. The electromagnetic 

radiation hazard exclusion area 

for personnel would extend for 

400 meters (1,312 feet) in front 

and to the side of the radar. 

 

The proposed action, among other 

things, was to site, 

install/construct and operate 

various radars, telemetry systems, 

communications equipment, and 

other essentially similar facilities 

and equipment at additional 

launch and test facilities at 

various locations, including the 

SBX in the Pacific Region. Most 

tests would include the launch of 

a target missile; tracking by range 

and other land-based, sea-based, 

airborne, and space-based 

sensors; launch of an interceptor 

missile; target intercept; and 

debris impacting into BOA of the 

Pacific Ocean. 

The proposed action, among other 

things, was to provide a mobile 

sea-based platform from which to 

more realistically test sensors 

(radars, telemetry, and optical

systems) in support of MDA’s 

mission. The MLP would also 

provide MDA the capability to 

use sensors at test support 

positions in remote areas of the 

ocean by locating these sensors 

on the MLP.

The proposed action was to use 

land-based mobile sensors (i.e., 

radar, telemetry and 

communication, command and 

control, and optical systems) and 

airborne sensor systems (i.e., 

optical and infrared systems) at 

various locations around the 

country. A test event may use 

any combination of mobile landbased and one of the airborne 

mobile sensors. The land-based 

mobile sensors would be 

transportable systems that could 

operate as autonomous systems or 

as part of an integrated sensor 

system. Airborne systems also 

could operate as autonomous 

systems, but typically would be 

part of an integrated sensor 

system.

The proposed action, among other 

things, was the operation of the 

SBX Radar while at the PSB and 

the use of onshore PSB assets and 

infrastructure to support SBX 

operations.

The proposed action, among 

other things, was the development 

or enhancement of BMDS 

sensors to acquire, record, and 

process data on threat missiles 

and interceptor missiles; detect 

and track threat missiles; direct 

interceptor missiles or other 

defenses (e.g., lasers); and assess 

whether a threat missile has been 

destroyed.

The proposed action in part was 

the siting, construction and 

operation of a second RIDT, at a 

site adjacent to the existing RIDT 

along El Rancho Road on 

Vandenberg AFB. 

Methods of 

Implementing 

the Action

Obtain test plan and CONOPs 

from MDA test proponent.

Work with host installation or 

property owner to find suitable 

location and permission to install 

and operate equipment.

Same Same Same Same Temporary placement. Same Permanent installation and 

operation.

155 October 2013
Benchmarking 

Categories MDA

Theater High Altitude Area 

Defense (THAAD) Pacific Test 

Flights Environmental 

Assessment, December 2002, 

FONSI Signed

Ground-Based Midcourse 

Defense (GMD) Extended Test 

Range (ETR) Environmental 

Impact Statement, July 2003

Mobile Launch Platform 

(MLP) Environmental 

Assessment, June 2004, FONSI 

Signed

Mobile Sensors Environmental 

Assessment, September 2005, 

FONSI Signed

Missile Defense Agency 

Ground-Based Midcourse 

Defense (GMD) Sea-Based XBand (SBX) Radar Placement 

and Operation Adak, Alaska, 

October 2005, FONSI Signed

Missile Defense Agency Ballistic 

Missile Defense System (BMDS) 

Programmatic Environmental 

Impact Statement, January 

2007

Relocatable In-Flight 

Interceptor Communications 

System Data Terminal (IDT) #2 

at Vandenberg Air Force Base, 

Supplemental Environmental 

Assessment, November 2007, 

FONSI Signed

Applicable 

CATEXs B-21

Work with host installation to 

identify applicable laws, 

regulations, and SOPs.

Work with host installation to 

either review existing 

documentation and/or prepare 

necessary NEPA documentation.

Work with host installation or 

property owner to conduct any 

required site preparation 

activities.

Deploy equipment to site, install, 

test, and operate equipment per 

Test CONOPs. 

Retrograde equipment and restore 

site to original condition (or 

agreed upon condition – e.g., 

leaving behind grounding grids or 

sound barriers).

Frequency of the 

Actions

Generally one time. However, at 

larger installations, MDA could 

conduct up to two tests/year at 

any given location.

One time Generally one time per location. 

Deployment could occur at two to 

three locations per year. 

MLP could be used two to three 

times per year.

Generally one time per location. 

Deployment could occur at two to 

three locations per year. 

Completed—SBX is currently at 

Pearl Harbor

Generally one time per location. 

Deployment could occur at two to 

three locations per year. 

One time – IDT operates 24/7

Applicable 

Regulations

NEPA, ESA, NHPA, ARPA, 

CERCLA, CWA, CAA, and other 

applicable Federal and state 

regulations, DoD and Service 

requirements, and industry 

standards.

Same Same Same Sa me Same Same Same

Applicable SOPs Installation/Manufacturer specific 

SOPs and BMPs

Same Same Same Same Same Same Same

Timing and 

Context

Radars and support equipment are 

used to support BMDS test events 

that could occur any time of the 

year. Equipment, many times, is 

tactical or operational equipment 

and is in short supply; therefore, 

it is moved to other locations as 

needed.

BMDS test events are conducted 

at host installations designed to 

conduct same types of testing. 

MDA relies on installation’s 

infrastructure and sensors. 

However, some BMDS 

Same Same Same Same Same Same 24 hours/7 days a week 

operations.

156 October 2013
Benchmarking 

Categories MDA

Theater High Altitude Area 

Defense (THAAD) Pacific Test 

Flights Environmental 

Assessment, December 2002, 

FONSI Signed

Ground-Based Midcourse 

Defense (GMD) Extended Test 

Range (ETR) Environmental 

Impact Statement, July 2003

Mobile Launch Platform 

(MLP) Environmental 

Assessment, June 2004, FONSI 

Signed

Mobile Sensors Environmental 

Assessment, September 2005, 

FONSI Signed

Missile Defense Agency 

Ground-Based Midcourse 

Defense (GMD) Sea-Based XBand (SBX) Radar Placement 

and Operation Adak, Alaska, 

October 2005, FONSI Signed

Missile Defense Agency Ballistic 

Missile Defense System (BMDS) 

Programmatic Environmental 

Impact Statement, January 

2007

Relocatable In-Flight 

Interceptor Communications 

System Data Terminal (IDT) #2 

at Vandenberg Air Force Base, 

Supplemental Environmental 

Assessment, November 2007, 

FONSI Signed

Applicable 

CATEXs B-21

components being tested are 

either the specific system under 

test or are brought in to augment 

those operated by the e 

range/installation. If adequate 

power is available from host 

installation, MDA will use 

available power. However, some 

systems require their own power. 

For example, the standalone 

tactical radar systems (e.g., the 

AN/TPY-2 radar) can either use 

available power or generator 

power; where as a missile 

interceptor and radar weapon 

system (e.g., THAAD or PAC-3 

systems) requires the use of their 

own tactical generators. Other 

times, for test reliability purposes, 

the system under test will run off 

of host power (or shore power) 

and use tactical or operational 

generators as backup. 

Extraordinary 

Circumstances

BMDS test events can be delayed 

and equipment could be left at a 

test site for a while longer (e.g., 

several months) than anticipated.

Presence of cultural, historical, 

biological resources or 

contamination.

Same Same Same Same Same Same Same

Known Impacts 

from Proposed 

Action

After 20+ years of testing, MDA 

knows of no known significant 

impacts from these types of 

activities including generator use 

beyond those resulting from 

accidental spills of fuel during 

fueling activities. Potential 

impacts are mitigated using spill 

containment equipment and 

fueling SOPs. Contaminated 

media is removed and treated 

IAW applicable regulations.

Over the course of 6 years, MDA 

conducted a-half dozen THAAD 

tests at the PMRF and no 

significant environmental impacts 

were observed as documented in 

mitigation monitoring reports.

Since the construction of the 

GMD ETR, MDA has conducted 

an average of one-two flight tests 

a year using sensors and radars 

and operated the SBX nearly 

continuously and no significant 

environmental impacts were 

observed.

The MLP has been used on 

average of two to five missions 

per year since 2005 and no 

significant environmental impacts 

have been observed.

MDA has conducted numerous 

test activities using mobile 

sensors and their supporting 

diesel-fueled generators and other 

support equipment and no

significant environmental impacts 

have been observed.

No significant environmental 

impacts were observed during the 

operation of the site. The SBX

has since vacated the site.

MDA has conducted at least four 

tests every year at locations 

around the world and no 

significant environmental impacts 

resulting from the use radars, 

sensors and support equipment 

including diesel-fueled generators

have been reported

No significant environmental 

impacts have been observed as a 

result of MDA’s construction and 

operation of the IDT #2 and 

supporting facilities.

157 October 2013
IV. ACRONYMS AND ABBREVIATIONS

ABIR Air-borne Infrared Radar

ABL Airborne Laser

ABV Alternate Boost Vehicle

ACM Asbestos containing material

AF813 Air Force Form 813

AFB Air Force Base

AFS Air Force Station

ANSI American National Standards Institute

AR Administrative Record

ARPA Archaeological Resources Protection Act

AT&C Assembly, Test, and Checkout

ATK Alliant Techsystems

AT&L Acquisition, Technology and Logistics

BCSC-T Ballistic Missile Defense System Communication Support ComplexTransportable

BMDS Ballistic Missile Defense System

BMP Best Management Practice

BRAC Base Realignment and Closure

BOA Broad Ocean Area

BOE Bureau of Explosives

BV Booster Vehicle

CAA Clean Air Act

CATEX Categorical Exclusion

C2BMC Command, Control, Battle Management and Communications

CEQ Council on Environmental Quality

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CFR Code of Federal Regulations

CONOPS Continuity of Operations

COTS Commercial-Off-The-Shelf

CWA Clean Water Act

D/D Dismantlement or Distruction

DF Deuterium Flouride

DAC Divert Altitude Control

DLA Defense Logistics Agency

DoD Department of Defense

DON Department of Navy

DOT Department of Transportation

DPF MDA Facilities, Military Construction and Environmental Management 

Directorate

DSE Distributed Sensing Equipment

EA Environmental Assessment

ECF Entry Control Facility

ECP Entry Control Point

EIS Environmental Impact Statement

158 October 2013
EKV Exo-atmospheric Kill Vehicle

EO Executive Order

EOD Explosive Ordnance Demolition

EPA Environmental Protection Agency

EPF Environmental Planning Function

ER Environmental Review

ERA Environmental Restoration Account

ESA Endangered Species Act

ETR Extended Test Range

EWR Early Warning Radar

FAA Federal Aviation Administration

FACO Final Assembly and Checkout Operations

FBX-T Forward-based X-band Transportable

FEMA Federal Emergency Management Agency

FOC Fiber Optic Cable

FONSI Finding of No Significant Impact

FTG Flight Test Ground-based Interceptor

GBI Ground-based Interceptor

GMD Ground-based Midcourse Defense

GPR Ground Penetrating Radar

GSA General Services Agency

HE High Explosive

HELSTF High Energy Laser System Test Facility

HMTA Hazardous Materials Transportation Act

HVAC Heating, Venting and Air Conditioning

IAW In Accordance With

ICRMP Integrated Cultural Resources Management Plan

IDOC Initial Defensive Operations Capability

IDT Integrated Data Terminal

IEEE Institute of Electrical and Electronics Engineers

IFT Integrated Flight Test

IMF Integrated Maintenance Facility

INRMP Integrated Natural Resources Management Plan

ISCP Installation Spill Contingency Plan

ISFAC Integrated Data Terminal Support Facility

ISTEF Innovative Science and Technology Experimentation Facility

KEI Kinetic Energy Interceptor

KPTS Kaena Point Satellite Tracking Station

LBP Lead-based Paint

LF Launch Facility

LFT&E Live Fire Test and Evaluation

LPM Liquid Propellant Missile

LPS Lightning Protection System

MAB Missile Assembly Building

MAF Missile Assembly Facility

MARAD Maritime Administration

159 October 2013
MDA Missile Defense Agency

MeV Mega Electron Volt

MIT/LL Massachusetts Institute of Technology/Lincoln Laboratory

MLP Mobile Launch Platform

MMH Monomethyl-hydrazine

MODUK Ministry of Defense, United Kingdom

MRSS Mobile Range Safety System

MS2 Mission Systems and Sensors

NASNI Naval Air Station North Island

NCR National Capital Region

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NMD National Missile Defense

N2O4 Dinitrogen Tetraoxide

NOAA National Oceanic and Atmospheric Administration

NSE Naval Station Everett

OSHA Occupational Safety and Health Act

OUSD Office of Under Secretary of Defense

PC Pacific Collector

PCB Polychlorinated biphenyls

PDS Protective Distribution System

PEA Programmatic Environmental Assessment

PEIS Programmatic Environmental Impact Statement

PL Protection Level

PMRF Pacific Missile Range Facility

PSB Primary Support Base

PT Pacific Tracker

RAMOS Russian-American Observation Satellites

RCE Record of Categorical Exclusion

RCRA Resource Conservation and Recovery Act

RDT&E Research, Development, Testing, and Evaluation

REC Record of Environmental Consideration

RIDT Relocatable Integrated Data Terminal

ROD Record of Decision

RSTS Range Safety Telemetry System

RV Re-entry Vehicle

SATCOM Satellite Communication

SBX Sea-Based X-Band

SEA Supplemental Environmental Assessment

SHOTS Stabilized High-Accuracy Optical Tracking System

SPCC Spill Prevention, Control and Countermeasures

SRMSC Stanley R. Mickelsen Safeguard Complex

SOP Standard Operating Procedure

SWFPAC Strategic Weapons Facility Pacific

TBP Tributyl Phosphate

THAAD Theater High Altitude Area Defense

160 October 2013
TMS Target Missile System

TPS-X Transportable System X-Band Radar

TRACS Transportable Range Augmentation Control System

TSCA Toxic Substances Control Act

TSMRI Ted Stevens Marine Research Institute

TTS Transportable Telemetry System

UES USAKA Environmental Standards

UPS Uninterrupted Power Supply

USAKA United States Army Kwajalein Atoll

USAF United States Air Force

USCG United States Coast Guard

USC United States Code

VOC Validation of Concept

WASP Wide Body Airborne Sensor Platform

WSMR White Sands Missile Range

161 October 2013
V. QUALIFICATION OF PREPARERS

Buff L. Crosby, Ph.D.

Qualifications: Dr. Crosby has over 20 years of experience in environmental compliance, 

environmental management (including land, water, and natural resource management), policy 

and environmental-related strategy development. Dr. Crosby has held several technical and 

leadership roles in a federal agency responsible for managing public lands, natural resource 

management, and improving water quality. Dr. Crosby is experienced in environmental policy 

development, Environmental Management Systems (EMS), National Environmental Policy Act 

(NEPA), Endangered Species Act (ESA) and National Historic Preservations Act (NHPA) 

compliance requirements.

Kevin L. Call

Qualifications: Over 25 years experience in environmental law, involving most major 

environmental disciplines, with an emphasis in NEPA law and practice, both as an active-duty 

Army Judge Advocate (JA) Officer and civilian attorney within the Army and DoD.

Mark Ethridge

Qualifications: Mr. Ethridge has 34 years of experience in environmental management and the 

analysis of environmental impact, regulatory compliance, and due diligence issues. 

Howard S. Finkel, P.E.

Qualifications: Mr. Finkel, P.E., is a registered environmental engineer with 30 years of 

experience in environmental science/engineering and regulatory analysis in the areas of: waste 

generation, characterization, and management; pollution prevention, environmental management 

systems, risk assessment; and environmental site assessments.

Eric N. Sorrells, PE

Qualifications: Over 25 years experience in facilities and environmental management, 

involving most major environmental disciplines, with an emphasis in NEPA compliance, both as 

an active-duty Naval Officer, contractor and government civilian within the Navy and DoD.

Daniel L. Spiegelberg, PE

Qualifications: A registered professional engineer with more than 40 years experience in 

environmental and facilities management, including 15 years experience in Ballistic Missile 

Defense System (BMDS) environmental management as a contractor and government employee,

20 years experience in environmental and facilities engineering and management as a 

commissioned officer in the United States Navy Civil Engineer Corps, and 6 years experience as 

a contractor providing environmental services to other federal clients.

162 October 2013
Joseph B. Venable, PE

Qualifications: More than 40 years experience in environmental and facilities management, 

which includes 13 years experience in Ballistic Missile Defense System (BMDS) 

environmental management and 25 years of military operations, facilities and utilities 

acquisition and engineering management experience as a commissioned officer in the Civil 

Engineer Corps, United States Navy.

George M. Wheeler, PE, PMP

Qualifications: A registered professional engineer with more than 36 years of progressive and 

successful engineering experience in the Department of Defense environment. He has performed 

independent engineering studies supporting facility infrastructure design and led or participated 

on multi-disciplinary study teams that analyzed facilities planning documents for regulatory 

compliance and technical feasibility, identified potential risks to cost, schedule, and 

performance, and proposed mitigation measures protective of the human environment and the 

government’s interests. He has managed environmental compliance and protection activities at a 

3,000 acre military facility, directed training and operations for engineer units comprising more 

than 900 personnel and multiple occupational specialties, and provided environmental 

compliance management advice at the military agency headquarters level. He holds advanced 

degrees in information systems and environmental engineering and is a certified Project 

Management Professional.

163 October 2013