DRAFT ENVIRONMENTAL ASSESSMENT

Construction of a Military Housing 

Development for U.S. Army 

Garrison-Miami, Doral, Florida

Prepared for

U.S. Army Garrison-Miami

Prepared by 

U.S. Army Corps of Engineers, Mobile District

January 2021
iii

Contents

Section Page

Acronyms and Abbreviations.............................................................................................................................ix

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

ES.1 Introduction.................................................................................................................................. ES-1

ES.2 Purpose and Need ........................................................................................................................ ES-1

ES.3 Proposed Action and Alternatives................................................................................................ ES-1

ES.3.1 Proposed Action .............................................................................................................. ES-1

ES.3.2 Alternatives...................................................................................................................... ES-2

ES.3.3 Alternatives Not Considered in Detail ............................................................................. ES-2

ES.4 Summary of Environmental Consequences.................................................................................. ES-3

ES.5 Summary of Project Design Measures.......................................................................................... ES-4

1 Purpose, Need, and Scope...................................................................................................................1-1

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

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

1.3 Scope ..............................................................................................................................................1-2

1.3.1 Resources Eliminated from Analysis..................................................................................1-2

1.3.2 Resource Areas Analyzed...................................................................................................1-3

1.4 Public Involvement .........................................................................................................................1-3

1.5 Relevant Statutes and Executive Orders ........................................................................................1-3

1.5.1 Federal Regulations...........................................................................................................1-4

1.5.2 Army Regulations...............................................................................................................1-4

1.5.3 Executive Orders................................................................................................................1-5

1.6 Organization of the Document.......................................................................................................1-5

2 Description of the Proposed Action and Alternatives ..........................................................................2-1

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

2.1.1 Construction Components.................................................................................................2-1

2.1.2 Operations Components....................................................................................................2-2

2.2 Alternatives.....................................................................................................................................2-2

2.2.1 Alternative 1 – MILCON Alternative ..................................................................................2-2

2.2.2 Alternative 2 – EUL Alternative .........................................................................................2-3

2.2.3 Alternative 3 – No Action Alternative................................................................................2-4

2.3 Alternatives Dismissed from Consideration ...................................................................................2-5

2.3.1 Alternative 4 – Privatized Housing on FAA Parcel .............................................................2-5

2.3.2 Alternative 5 – MILCON Family Housing Project near Homestead Air 

Reserve Base......................................................................................................................2-5

2.3.3 Alternative 6 – Expanded Leasing (in Doral Only) .............................................................2-5

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

3.1 Introduction....................................................................................................................................3-1

3.1.1 Direct versus Indirect Effects.............................................................................................3-1

3.1.2 Short-term versus Long-term Effects ................................................................................3-1

3.1.3 Intensity of Effects.............................................................................................................3-2

3.1.4 Significance ........................................................................................................................3-2

3.1.5 Mitigation ..........................................................................................................................3-2

3.2 Land Use .........................................................................................................................................3-2

3.2.1 Affected Environment .......................................................................................................3-2
CONTENTS

Section Page

iv

3.2.2 Environmental Consequences...........................................................................................3-3

3.3 Soils.................................................................................................................................................3-4

3.3.1 Affected Environment .......................................................................................................3-4

3.3.2 Environmental Consequences...........................................................................................3-4

3.4 Groundwater ..................................................................................................................................3-5

3.4.1 Affected Environment .......................................................................................................3-5

3.4.2 Environmental Consequences...........................................................................................3-6

3.5 Surface Water.................................................................................................................................3-7

3.5.1 Affected Environment .......................................................................................................3-7

3.5.2 Environmental Consequences...........................................................................................3-7

3.6 Water Quality .................................................................................................................................3-8

3.6.1 Affected Environment .......................................................................................................3-8

3.6.2 Environmental Consequences...........................................................................................3-8

3.7 Flood Hazards .................................................................................................................................3-9

3.7.1 Affected Environment .......................................................................................................3-9

3.7.2 Environmental Consequences...........................................................................................3-9

3.8 Air Quality .....................................................................................................................................3-10

3.8.1 Regulatory Setting ...........................................................................................................3-10

3.8.2 Affected Environment .....................................................................................................3-12

3.8.3 Environmental Consequences.........................................................................................3-12

3.9 Noise .............................................................................................................................................3-15

3.9.1 Affected Environment .....................................................................................................3-15

3.9.2 Environmental Consequences.........................................................................................3-16

3.10 Biological Resources.....................................................................................................................3-17

3.10.1 Regulatory Considerations ..............................................................................................3-17

3.10.2 Affected Environment .....................................................................................................3-17

3.10.3 Environmental Consequences.........................................................................................3-20

3.11 Cultural Resources........................................................................................................................3-22

3.11.1 Affected Environment .....................................................................................................3-22

3.11.2 Environmental Consequences.........................................................................................3-22

3.12 Socioeconomic Resources ............................................................................................................3-22

3.12.1 Affected Environment .....................................................................................................3-22

3.12.2 Environmental Consequences.........................................................................................3-23

3.13 Coastal Zone Management...........................................................................................................3-25

3.13.1 Affected Environment .....................................................................................................3-25

3.13.2 Environmental Consequences.........................................................................................3-25

3.14 Safety and Occupational Health ...................................................................................................3-25

3.14.1 Affected Environment .....................................................................................................3-25

3.14.2 Environmental Consequences.........................................................................................3-26

3.15 Hazardous Materials.....................................................................................................................3-27

3.15.1 Affected Environment .....................................................................................................3-27

3.15.2 Environmental Consequences.........................................................................................3-27

3.16 Traffic and Transportation............................................................................................................3-31

3.16.1 Affected Environment .....................................................................................................3-31

3.16.2 Environmental Consequences.........................................................................................3-31

3.17 Recreation.....................................................................................................................................3-32

3.17.1 Affected Environment .....................................................................................................3-32

3.17.2 Environmental Consequences.........................................................................................3-33

3.18 Utilities..........................................................................................................................................3-33

3.18.1 Affected Environment .....................................................................................................3-33
CONTENTS

Section Page

v

3.18.2 Environmental Consequences.........................................................................................3-34

3.19 Visual Resources...........................................................................................................................3-35

3.19.1 Affected Environment .....................................................................................................3-35

3.19.2 Environmental Consequences.........................................................................................3-35

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

4.1 Introduction....................................................................................................................................4-1

4.1.1 Projects Identified with the Potential for Cumulative Effects...........................................4-1

4.2 Land Use .........................................................................................................................................4-1

4.2.1 MILCON Alternative...........................................................................................................4-1

4.2.2 EUL Alternative ..................................................................................................................4-2

4.2.3 No Action Alternative ........................................................................................................4-2

4.3 Soils.................................................................................................................................................4-2

4.3.1 MILCON Alternative...........................................................................................................4-2

4.3.2 EUL Alternative ..................................................................................................................4-2

4.3.3 No Action Alternative ........................................................................................................4-2

4.4 Groundwater ..................................................................................................................................4-2

4.4.1 MILCON Alternative...........................................................................................................4-2

4.4.2 EUL Alternative ..................................................................................................................4-2

4.4.3 No Action Alternative ........................................................................................................4-3

4.5 Surface Water.................................................................................................................................4-3

4.5.1 MILCON Alternative...........................................................................................................4-3

4.5.2 EUL Alternative ..................................................................................................................4-3

4.5.3 No Action Alternative ........................................................................................................4-3

4.6 Water Quality .................................................................................................................................4-3

4.6.1 MILCON Alternative...........................................................................................................4-3

4.6.2 EUL Alternative ..................................................................................................................4-3

4.6.3 No Action Alternative ........................................................................................................4-3

4.7 Flood Hazards .................................................................................................................................4-4

4.7.1 MILCON Alternative...........................................................................................................4-4

4.7.2 EUL Alternative ..................................................................................................................4-4

4.7.3 No Action Alternative ........................................................................................................4-4

4.8 Air Quality .......................................................................................................................................4-4

4.8.1 MILCON Alternative...........................................................................................................4-4

4.8.2 EUL Alternative ..................................................................................................................4-4

4.8.3 No Action Alternative ........................................................................................................4-4

4.9 Noise ...............................................................................................................................................4-5

4.9.1 MILCON Alternative...........................................................................................................4-5

4.9.2 EUL Alternative ..................................................................................................................4-5

4.9.3 No Action Alternative ........................................................................................................4-5

4.10 Biological Resources.......................................................................................................................4-5

4.10.1 MILCON Alternative...........................................................................................................4-5

4.10.2 EUL Alternative ..................................................................................................................4-5

4.10.3 No Action Alternative ........................................................................................................4-5

4.11 Cultural Resources..........................................................................................................................4-6

4.11.1 MILCON Alternative...........................................................................................................4-6

4.11.2 EUL Alternative ..................................................................................................................4-6

4.11.3 No Action Alternative ........................................................................................................4-6

4.12 Socioeconomic Resources ..............................................................................................................4-6

4.12.1 MILCON Alternative...........................................................................................................4-6
CONTENTS

Section Page

vi

4.12.2 EUL Alternative ..................................................................................................................4-6

4.12.3 No Action Alternative ........................................................................................................4-6

4.13 Coastal Zone Management.............................................................................................................4-6

4.13.1 MILCON Alternative...........................................................................................................4-6

4.13.2 EUL Alternative ..................................................................................................................4-7

4.13.3 No Action Alternative ........................................................................................................4-7

4.14 Safety and Occupational Health .....................................................................................................4-7

4.14.1 MILCON Alternative...........................................................................................................4-7

4.14.2 EUL Alternative ..................................................................................................................4-7

4.14.3 No Action Alternative ........................................................................................................4-7

4.15 Hazardous Materials.......................................................................................................................4-7

4.15.1 MILCON Alternative...........................................................................................................4-7

4.15.2 EUL Alternative ..................................................................................................................4-7

4.15.3 No Action Alternative ........................................................................................................4-7

4.16 Traffic and Transportation..............................................................................................................4-8

4.16.1 MILCON Alternative...........................................................................................................4-8

4.16.2 EUL Alternative ..................................................................................................................4-8

4.16.3 No Action Alternative ........................................................................................................4-8

4.17 Recreation.......................................................................................................................................4-8

4.17.1 MILCON Alternative...........................................................................................................4-8

4.17.2 EUL Alternative ..................................................................................................................4-8

4.17.3 No Action Alternative ........................................................................................................4-8

4.18 Utilities............................................................................................................................................4-9

4.18.1 MILCON Alternative...........................................................................................................4-9

4.18.2 EUL Alternative ..................................................................................................................4-9

4.18.3 No Action Alternative ........................................................................................................4-9

4.19 Visual Resources.............................................................................................................................4-9

4.19.1 MILCON Alternative...........................................................................................................4-9

4.19.2 EUL Alternative ..................................................................................................................4-9

4.19.3 No Action Alternative ........................................................................................................4-9

5 References..........................................................................................................................................5-1

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

7 Distribution List ..................................................................................................................................7-1

8 Persons Consulted ..............................................................................................................................8-1

Appendices

A Government Correspondence

B Coastal Zone Consistency Determination

C FONSI and Public Comments

D Air Quality Emission Estimates and Record of Non-Applicability

E Special-status Species Descriptions

Tables

ES-1 Summary of Project Design Measures

ES-2 Summary of Potential Environmental and Socioeconomic Consequences

3-1 National Ambient Air Quality Standards
CONTENTS

Section Page

vii

3-2 MILCON Alternative Emissions

3-3 EUL Alternative Emissions

3-4 Protected Plant Species with Potential to Occur in the Proposed Project Area

3-5 Protected Wildlife Species with Potential to Occur in the Proposed Project Area

6-1 List of Preparers

Figures

1-1 Proposed Project Location

2-1 MILCON Alternative

2-2 Enhanced Use Lease Alternative

3-1 FAA Safety Setbacks
ix

Acronyms and Abbreviations

μg/m3 microgram per cubic meter

amsl above mean sea level 

AR Army Regulation

Army U.S. Army

BMP Best Management Practice

CAA Clean Air Act

CEQ Council on Environmental Quality

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

CO carbon monoxide

CO2 carbon dioxide

CO2e carbon dioxide equivalent

CWA Clean Water Act

CZMA Coastal Zone Management Act

dB decibel

dBA A-weighted decibel

dBC C-weighted decibel

DNL Day-Night Average Sound Level 

DoD Department of Defense

EA Environmental Assessment

ECP Environmental Condition of Property

EO Executive Order

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act

EUL Enhanced Use Lease

FAA Federal Aviation Administration

FAC Florida Administrative Code 

FDEP Florida Department of Environmental Protection 

FEMA Federal Emergency Management Agency

FIRM Flood Insurance Rate Map

FONSI Finding of No Significant Impact

FPPA Farmland Protection Policy Act of 1981

FY fiscal year
ACRONYMS AND ABBREVIATIONS

x

GHG greenhouse gas

K&E key and essential

MBTA Migratory Bird Treaty Act

MILCON military construction

NA not applicable

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NO2 nitrogen dioxide

NOx nitrogen oxides

NSR New Source Review

O3 ozone

OSHA Occupational Safety and Health Administration

PM10 particulate matter less than or equal to 10 micrometers in diameter

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

ppm parts per million

RCRA Resource Conservation and Recovery Act 

RF radiofrequency

RCI Residential Communities Initiative

SFWMD South Florida Water Management District

SO2 sulfur dioxide

SOUTHCOM U.S. Southern Command

SWPPP Stormwater Pollution Prevention Plan

U.S. United States

USDOT U.S. Department of Transportation

UFC Unified Facilities Criteria

USAG-Miami U.S. Army Garrison-Miami

U.S.C. United States Code

USFWS U.S. Fish and Wildlife Service

VOC volatile organic compound

WASD Water and Sewer Department
ES-1

Executive Summary

ES.1 Introduction

This Environmental Assessment (EA) analyzes the potential environmental consequences resulting from 

implementation of the Proposed Action to provide quality military housing at U.S. Army Garrison-Miami (USAGMiami).

USAG-Miami is in Doral, Florida in Miami-Dade County, approximately 3 miles west of Miami International Airport 

(Figure 1-1). A major tenant of USAG-Miami in Doral is U.S. Southern Command (SOUTHCOM). USAG-Miami also 

supports SOUTHCOM’s subordinate commands, U.S. Marine Forces South and Special Operations Command 

South, in Homestead, Florida as well as various other organizations.

There is no military housing on the USAG-Miami cantonment. This creates significant financial, security, and 

quality of life issues for service members and adversely affects mission readiness (USAG-Miami, 2018). USAGMiami proposes to secure military housing on purchased or leased land near SOUTHCOM headquarters to address 

this housing shortfall.

ES.2 Purpose and Need

The purpose of the Proposed Action is to provide military housing for USAG Miami’s housing requirement. This 

includes housing for 50 Key and Essential Family Units and 120 Unaccompanied Enlisted Units within 5 miles/15 

minutes peak traffic commute from SOUTHCOM headquarters in Doral, Florida. This ensures essential personnel 

can walk to the installation and enables mission readiness. The remainder of the housing requirement (120 Family 

Units) should be within 20 miles/60 minutes peak traffic commute from SOUTHCOM headquarters. The need for 

the Proposed Action is to minimize mission interruption during emergency conditions and to improve security and 

readiness, increase affordability, and provide cohesion for families and staff. There is no military housing on the 

USAG-Miami cantonment and no space within the cantonment to construct military housing; therefore, service 

members are forced to seek affordable housing within the local economy. The absence of housing on the 

installation presents a mission sustainment problem because essential personnel may be unable to reach the 

SOUTHCOM facility during an emergency to maintain operations because of road closures and traffic, and it 

makes it difficult to provide required security and protection for the combatant commander and key and essential 

(K&E) and mission essential personnel. Moreover, there is a documented shortfall of affordable housing around 

USAG-Miami (USAG-Miami, 2018).

ES.3 Proposed Actionand Alternatives

ES.3.1 Proposed Action

The Proposed Action is for USAG-Miami to acquire land owned by the Federal Aviation Administration (FAA) south 

of NW 33rd Street across from the SOUTHCOM headquarters in Doral, Florida and construct a military housing 

development on the property. The property houses a large FAA radar tower and associated support buildings near 

its center. No housing development would be constructed within the FAA established antenna standoff area to 

avoid interference with operation of the radar system; however, non-vertical assets such as stormwater retention

infrastructure, roads, or parking may be located within this radius. The Proposed Action would meet most of the 

USAG-Miami 2020 military housing shortfalls described in the Purpose and Need (Section 1.2).
EXECUTIVE SUMMARY

ES-2

ES.3.2 Alternatives

Alternative 1 – MILCON Alternative

In the Military Construction (MILCON) Alternative, USAG-Miami would use congressionally approved funds to 

acquire some or all of the approximately 160-acre FAA parcel and pay for the construction, operation, 

management, and maintenance of service member housing on up to 75 acres of the property (Figure 2-1). The 

MILCON Alternative would consist of constructing and operating a housing development as described in the 

Proposed Action (Section 2.1). Under this alternative, no building structures would be built on the central portion 

(52.4 acres) of the parcel as not to interfere with radar tower operations; however, non-vertical assets such as 

stormwater retention infrastructure, roads, or parking may be located within this radius.

Alternative 2 – EUL Alternative

In the Enhanced Use Lease (EUL) Alternative, USAG-Miami would obtain an EUL agreement with a private 

developer to construct and operate a housing development on the approximately 160-acre FAA parcel (Figure 2-

2). This alternative would consist of constructing and operating a housing development as described in the 

Proposed Action (Section 2.1) on up to 75 acres of the northern portion of the FAA parcel. In addition, up to 32.5 

acres of the southern portion of the FAA parcel would be offered to a developer for a mixed-use development in 

exchange for funding the construction of the military housing. The southern development would include up to 

302,000 square feet of retail space below two levels of 167 apartments and would include up to 806 parking 

spaces. The total footprint, including residential, retail, and parking spaces would be up to 107.5 acres. Under this 

alternative, no building structures would be built on the central portion (52.4 acres) of the parcel as not to 

interfere with radar tower operations; however, non-vertical assets such as stormwater retention infrastructure, 

roads, or parking may be located within this radius.

Alternative 3 – No Action Alternative

Under the No Action Alternative, USAG-Miami would not acquire the FAA parcel directly adjacent to the 

SOUTHCOM headquarters in Doral, Florida and would not construct a military housing development. Service 

members would continue to search for affordable housing within the local economy and be scattered across the 

city and county. This would continue to create an undue financial burden on many service members as they seek 

suitable quarters and would continue to adversely impact mission readiness for USAG-Miami and SOUTHCOM. 

Essential personnel would continue to be unable to quickly reach the SOUTHCOM headquarters facility to 

maintain operations during emergencies as a result of possible road closures and traffic. Higher-level personnel 

living offsite would not be provided with required additional security for personal protection. 

Under the No Action Alternative, revisiting the option of acquiring the FAA parcel a few years from now may not 

be a possibility. FAA is systematically updating traffic control systems, and the large satellite dish at the FAA parcel

may become obsolete. If FAA opts to dispose of this property and the Army is not in the position to acquire it, an 

opportunity to enhance the SOUTHCOM mission and improve service members’ quality of life would be lost.

The No Action Alternative would not address the purpose and need for the Proposed Action. The No Action 

Alternative is included for analysis as required by National Environmental Policy Act (NEPA) and serves as 

reference for comparison of potential effects of the Proposed Action.

ES.3.3 Alternatives Not Considered in Detail

USAG-Miami developed the Proposed Action and alternatives based on consideration of mission requirements, 

security requirements, environmental constraints, and mission efficiency. Five alternatives for meeting housing 

shortfalls at USAG-Miami were evaluated in a cost-benefit analysis (USAG-Miami, 2018). Alternatives dismissed 

from further consideration are described below.

Alternative 4 – Privatized Housing on FAA Parcel

Under Alternative 4, privatized housing would be constructed on the 160-acre FAA parcel. The Residential 

Communities Initiative (RCI), the most common form of housing privatization, has been widely used on military 
EXECUTIVE SUMMARY

ES-3

bases. The authority to use this model has recently expired. If the authority could be restarted, this model 

leverages the Basic Allowance for Housing to access the private capital market to fund construction and 

maintenance without congressionally approved funds. 

Alternative 4 requires a new privatization authority and needs an Army-level feasibility review. Because of limited 

scope and financial uncertainties, this alternative might be unattractive to an RCI partner. For economic viability, 

civilian occupancy of the housing development may eventually be required. Allowing civilians in the secure 

perimeter could jeopardize service members’ safety. Security also would be compromised if other government 

personnel are permitted to lease units. As a result of the aforementioned factors, Alternative 4 was dismissed 

from further consideration.

Alternative 5 – MILCON Family Housing Project near Homestead Air Reserve Base

Under Alternative 5, MILCON funds would be used to construct a housing development on other Real Property 

near Homestead Air Reserve Base, approximately 26 miles south of USAG-Miami. The land of the former 

Homestead Air Force Base was transferred to the Air Force Reserve and to Miami-Dade County following closure 

of the Air Force Base. USAG-Miami currently manages the operational facilities of Special Operations Command 

South on an 84.2-acre leased site owned by Miami-Dade County. USAG-Miami was directed by the Army to 

evaluate building on adjacent land owned by Miami-Dade County. The cost to acquire land, if available, would be 

an estimated $10,147,966.

Constructing housing in Homestead would exacerbate rather than solve most of the issues SOUTHCOM is trying to 

resolve. Availability of suitable land for this project is assumed; however, no suitable contiguous tracts of land are 

available that meet the requirement. Furthermore, the drive time between the two locations averages between 

40 and 45 minutes without traffic issues, and all major routes require tolls of approximately $5 per day for the 

drive. K&E personnel could not be assigned in Doral and housed in Homestead. Homestead suffers from a lack of 

acceptable childcare, schools, and healthcare (USAG-Miami, 2018). As a result of the aforementioned factors, 

Alternative 5 was dismissed from further consideration.

Alternative 6 – Expanded Leasing (in Doral Only)

Alternative 6 is similar to the No Action Alternative but would require the housing office to lease, rent, or buy real 

estate in the corporate limits of Doral and assign it to personnel. This variation on the No Action Alternative limits 

many of the negative aspects of the No Action Alternative. An increase in housing office personnel would be 

required to validate that homes meet Army requirements and maintain the pool of residences. 

This alternative has the highest cost and does not improve service member security. A large increase in the 

Directorate of Public Works Housing Office staff would be required, and service members would face high upfront 

costs in the Doral rental market. Additionally, personnel could encounter traffic and road closures that could delay 

their ability to quickly reach the installation in an emergency. This alternative was dismissed from further 

consideration because it does not meet the purpose and need of the Proposed Action.

ES.4 Summary of Environmental Consequences

This EA presents a comprehensive evaluation of the existing conditions and environmental consequences of 

implementing the MILCON Alternative, EUL Alternative, and No Action Alternative, as required by NEPA. Three 

categories of potential impacts were evaluated: direct, indirect, and cumulative. A direct impact is the result of 

direct action and occurs at the same time and place. An indirect impact is caused by an action and occurs later in 

time or removed in distance, but still reasonably foreseeable. A cumulative impact results from the incremental 

impact of the action when combined with other past, present, and reasonably foreseeable future actions 

regardless of what agency or person undertakes such other action. 

Based on the findings of this EA, implementation of the Proposed Action would not have significant adverse 

direct, indirect, or cumulative effects on the quality of the environment. 
EXECUTIVE SUMMARY

ES-4

Under the No Action Alternative, no changes to baseline conditions would occur. While this would likely not result 

in significant direct or indirect impacts to resource areas, it would fail to accomplish the Proposed Action’s

purpose and need.

Table ES-2 summarizes the consequences of the MILCON Alternative, EUL Alternative, and the No Action 

Alternative.

ES.5 Summary of Project Design Measures

Measures would be implemented to ensure that adverse environmental impacts of construction and operation of 

the implemented alternative would be avoided or minimized. These measures would be incorporated into the 

final design, implemented by the contractor, and included in the contract documents. A summary of project 

design measures is presented in Table ES-1.

Table ES-1. Summary of Project Design Measures 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Resource Area Proposed Project Design Measures

Air Quality Sprinkling/irrigation, vegetative cover, and mulching would be used as dust abatement measures 

during construction.

Noise Construction and demolition activities would be limited to typical, daytime working hours estimated 

to be between 7:30 a.m. and 6:30 p.m. Workers would be required to wear appropriate hearing 

protection.

Soils Sediment barriers (silt fence or straw wattles), temporary detention basins, grade stabilization with 

seed and mulch, and geotextile slope stabilization would be used to minimize impacts on soils.

Surface Water Sediment barriers (silt fence or straw wattles), temporary detention basins, grade stabilization with 

seed and mulch, and geotextile slope stabilization would be used to minimize erosion and transport 

of sediments to surface waters. 

Stormwater Silt fencing, guttering, and other flow control measures, detention and infiltration areas, and 

oil/water separators would be used to minimize onsite and downstream impacts from stormwater 

during and after construction.

Transportation Clearly indicated detours and traffic control signalers would be used to keep traffic moving during 

periods of heavy construction-related traffic or temporary road closures.

Hazardous Materials Implement a project-specific site safety plan to avoid significant risks and health hazards associated 

with the use of hazardous materials and hazardous waste generation and disposal.
EXECUTIVE SUMMARY

ES-5

Table ES-2. Summary of Potential Environmental and Socioeconomic Consequences 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Environmental and Socioeconomic Consequences

Resource No Action MILCON Alternative EUL Alternative

Land Use No impact Negligible long-term adverse direct impact as change 

(pasture converted to housing) would be consistent with 

land use designation. No adverse indirect impacts to land 

use. 

Negligible long-term adverse direct impact as change (pasture 

converted to housing and mixed-use development) would be 

consistent with land use designation. No adverse indirect impacts to 

land use.

Geology and Soils

Soils No impact Moderate long-term adverse direct impacts from site 

preparation and construction. Appropriate BMPs would 

be implemented to minimize erosion and impact from 

stormwater runoff. Negligible short-term adverse 

indirect impacts to soils from construction stormwater 

runoff. Minor long-term indirect adverse impacts to soils 

from an increase in impervious surface.

Moderate long-term adverse impacts from site preparation and 

construction. This alternative would have a greater impact on soils 

(43 percent greater area of disturbance) compared to the MILCON 

Alternative; however, with implementation of erosion and 

sedimentation controls and appropriate BMPs, the direct impacts 

are still expected to be moderate. Negligible short-term adverse 

indirect impacts to soils from construction stormwater runoff. 

Negligible long-term indirect adverse impacts to soils from an 

increase in impervious surface.

Water Resources

Groundwater No impact Negligible long-term indirect adverse impacts from 

construction and operation due to the size of the 

development (75 acres) compared with the size of the 

aquifer (4,000 square miles). Appropriate BMPs would be 

used to minimize impacts from stormwater runoff to 

groundwater recharge zones.

Negligible long-term indirect adverse impacts from construction 

and operation due to the size of the development (107.5 acres) 

compared with the size of the aquifer (4,000 square miles). Appropriate BMPs would be used to minimize impacts from 

stormwater runoff to groundwater recharge zones.

Surface Water No impact No more than negligible short-term direct impacts to 

surface water resources from construction activities. No 

more than negligible direct and indirect adverse long- term impact to surface water resources during operation 

due to post-construction stormwater controls 

implemented for the increase in impervious area (~50 

acres). Potential adverse impacts to surface water quality 

from spills would be minimized by properly storing 

materials and fueling and maintaining construction 

equipment offsite or in designated areas with 

appropriate control and containment.

Minor short-term direct impacts to surface water resources from 

construction activities. Minor to moderate adverse direct effects to 

surface water resources during operations. This alternative would 

have a greater impact on surface waters due to the larger area of 

impervious surface (approximately 82 acres) but due to 

implementation of post-construction stormwater controls the 

impacts to surface waters would still be less than significant. 

Potential adverse impacts to surface water quality from spills would 

be minimized by properly storing materials and fueling and 

maintaining construction equipment offsite or in designated areas 

with appropriate control and containment.

Wetlands No impact No impact No impact

Water Quality No impact No more than negligible long-term adverse direct

impacts to water quality due to implementation of 

appropriate BMPs to minimize potential for impacts from 

stormwater runoff and sedimentation caused by an 

increase in impervious area, approximately 50 acres.

No more than negligible long-term adverse direct impacts to water 

quality. This alternative would have a greater impact on water 

quality due to the larger area of impervious surface (approximately 

82 acres) but with implementation of the appropriate BMPs which 

would minimize potential for impacts from stormwater runoff and 

sedimentation caused by the increase in impervious area the 

impacts would still be negligible.
EXECUTIVE SUMMARY

ES-6

Table ES-2. Summary of Potential Environmental and Socioeconomic Consequences 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Environmental and Socioeconomic Consequences

Resource No Action MILCON Alternative EUL Alternative

Flood Hazards No impact Minor long-term adverse direct impact to flood hazard 

area from raising the ground surface using fill to above 

Base Flood Elevation. There would be less than 

significant long-term adverse indirect impacts from an 

increase impervious surface because the stormwater 

controls would minimize runoff increase and because 

project area would be less than 0.1 percent of the 

surrounding area, which would result in less than 0.01 

inch in rise of floodwater in the region.

Minor long-term adverse direct impact to flood hazard area from 

raising the ground surface using fill to above Base Flood Elevation.

There would be less than significant long-term adverse indirect 

impacts from an increase in impervious surface because the

stormwater controls would minimize runoff increase and because 

project area would be less than 0.1 percent of the surrounding area, 

which would result in less than 0.01 inch in rise of floodwater in the 

region.

Air Quality No impact Minor short-term adverse direct impacts on overall air 

quality from construction activities. Use of 

sprinkling/irrigation, vegetative cover, and mulching as 

dust abatement measures during construction.

Minor long-term adverse direct impacts on overall air 

quality from operational activities.

While emissions would be greater than the MILCON Alternative due 

to the larger area and longer construction duration, the project 

emissions would still be under air quality thresholds and effects 

would be comparable to the MILCON Alternative.

Minor short-term adverse direct impacts on overall air quality from 

construction activities. Use of sprinkling/irrigation, vegetative cover, 

and mulching as dust abatement measures during construction.

Minor long-term adverse direct impacts on overall air quality from 

operational activities.

Noise No impact Moderate short-term adverse direct noise impacts 

during construction from heavy equipment. Construction 

and demolition activities would be limited to typical 

working hours. Workers would be required to wear 

appropriate hearing protection. Negligible long-term 

adverse indoor direct impacts from noise would be 

expected at any of the proposed residences within the 

65-70 DNL noise contour for the Miami International 

Airport. No long-term adverse direct impacts to noise- sensitive receptors from operational activities.

Moderate short-term adverse noise impacts during construction 

from heavy equipment. Construction and demolition activities 

would be limited to typical working hours. Workers would be 

required to wear appropriate hearing protection. Negligible longterm adverse indoor direct impacts from noise would be expected 

at any of the proposed residences within the 65-70 DNL noise 

contour for the Miami International Airport. Negligible long-term

adverse direct impacts to noise-sensitive receptors from 

operational activities. 

Biological Resources

Vegetation No impact Less than significant long-term adverse direct impact

from removal of vegetation during construction.

While the area disturbed would be greater than for the MILCON 

Alternative, there would be less than significant long-term adverse 

direct impact from removal of vegetation during construction.

Wildlife No impact Minor short-term adverse direct impact from noise, 

construction activities and heavy equipment use. Minor 

long-term adverse direct impacts from habitat removal.

Minor short-term adverse direct impact from noise, construction 

activities, and heavy equipment use. Less than significant long-term 

impacts from habitat removal.
EXECUTIVE SUMMARY

ES-7

Table ES-2. Summary of Potential Environmental and Socioeconomic Consequences 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Environmental and Socioeconomic Consequences

Resource No Action MILCON Alternative EUL Alternative

Special-status 

Species

No impact Potential negligible short-term adverse direct impacts to

the State listed Southeastern American kestrel and 

Florida burrowing owl may occur(although unlikely) and 

would be limited to displacement of foraging animals. No 

impact to special-status plant species. If any protected 

species are observed within the construction areas, 

construction would stop until the protected species 

voluntarily leaves the construction area.

Potential negligible short-term adverse direct impacts to the State 

listed Southeastern American kestrel and Florida burrowing owl 

may occur(although unlikely) and would be limited to displacement 

of foraging animals. No impact to special-status plant species. If any 

protected species are observed within the construction areas, 

construction would stop until the protected species voluntarily 

leaves the construction area.

Cultural Resources No impact No impact No impact

Socioeconomic Resources

Economic 

Development

No impact Minor to moderate short-term beneficial impact on local 

economy associated with construction employment and 

wages. Negligible long-term adverse direct impact to 

local economy from loss of cattle grazing on the FAA 

parcel.

Minor to moderate short-term beneficial impacts on local economy 

associated with construction employment and wages. Negligible 

long-term adverse direct impact to local economy from loss of 

cattle grazing on the FAA parcel.

Minor to moderate long-term beneficial direct impact on the local 

economy from new business opportunities and jobs associated with 

commercial-use property.

Public 

Services

No impact Negligible to minor long-term adverse direct impact to 

fire, police, emergency, and medical services, and 

schools from increase in permanent residents.

Adverse impacts to public services under the EUL Alternative would 

be greater than the MILCON due to additional patrons and 

residents with the larger development, but with the capacity of the 

area services, the level of impacts of the project would be negligible 

to minor long-term adverse direct impact to fire, police, emergency, 

and medical services, and schools.

Housing No impact Moderate long-term beneficial impacts to housing 

availability in the local region.

The EUL Alternative would have a greater beneficial impact on 

housing compared with the MILCON Alternative due to the creation 

of publicly available housing but would still result in moderate long- term beneficial impacts to housing availability in the local region.

Coastal Zone 

Management

No impact Long-term adverse effects are due to constructing 

permanent structures within the coastal zone. The 

impacts are considered negligible because the proposed 

action remains consistent with the enforceable 

provisions of the Florida Coastal Zone Management Plan.

. Long-term adverse effects are due to constructing permanent 

structures within the coastal zone. The impacts are considered 

negligible because the proposed action remains consistent with the 

enforceable provisions of the Florida Coastal Zone Management 

Plan.
EXECUTIVE SUMMARY

ES-8

Table ES-2. Summary of Potential Environmental and Socioeconomic Consequences 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Environmental and Socioeconomic Consequences

Resource No Action MILCON Alternative EUL Alternative

Safety and 

Occupational 

Health

No impact Minor short-term adverse direct impacts from 

construction hazards. Appropriate safety plans and OSHA 

regulations would be followed to limit the risk of 

accidents. 

No construction would occur within the radio frequency 

(RF) radiation setback area and no housing or activity 

areas would be placed where exposure to dangerous 

radiation could occur. There would be no adverse 

impacts resulting from exposure of construction workers 

or residents of the housing development to RF radiation 

associated with the FAA antenna.

Minor short-term adverse direct impacts from construction hazards. 

While the construction area would be greater than for the MILCON 

Alternative, the level of impacts would be similar because 

appropriate safety plans and OSHA regulations would be followed 

to limit the risk of accidents.

No construction would occur within the radio frequency (RF) 

radiation setback area and no housing or activity areas would be 

placed where exposure to dangerous radiation could occur. There 

would be no adverse impacts resulting from exposure of 

construction workers or residents of the housing development to RF 

radiation associated with the FAA antenna would occur.

Hazardous 

Materials

No impact Negligible short-term adverse direct and indirect impacts 

from use of small quantities of potentially hazardous 

materials (e.g., gasoline, oils, coolant, lubricants, paints, 

solvents, etc.) during construction. Waste would be 

handled and disposed of in accordance with federal and 

state regulations. BMPs documented in a stormwater 

pollution prevention plan and/or a project-specific 

construction safety plan would be followed to avoid 

significant risks or health hazards.

Negligible short-term adverse direct and indirect impacts from use 

of small quantities of potentially hazardous materials (e.g., gasoline, 

oils, coolant, lubricants, paints, solvents, etc.) during construction. 

Waste would be handled and disposed of in accordance with 

federal and state regulations. While the construction area would be 

greater than for the MILCON Alternative, the level of impacts would 

be similar because of implementation of BMPs documented in a 

project-specific construction plan. 

Traffic and 

Transportation

No impact Minor short-term adverse direct impact on emergency 

vehicle response times from an increase in construction- related traffic.

Moderate short-term adverse direct impacts during 

construction of the connector road between the housing 

development and SOUTHCOM. Minor short-term 

adverse direct impacts from an increase in construction 

and personal vehicles along local roads during 

construction.

Long-term minor adverse direct impacts on local traffic 

from an increase in personal vehicle use by residents of 

the new housing development.

There would be a negligible long-term beneficial impact 

to regional traffic because SOUTHCOM personnel would 

not need to commute through local roads to work.

The EUL Alternative would have a greater impact on traffic and 

transportation compared to the MILCON Alternative; however, 

impacts would be similar as outlined below.

Minor short-term adverse direct impact on emergency vehicle 

response times from an increase in construction-related traffic.

Moderate short-term adverse direct impacts during construction of 

the connector road between the housing development and 

SOUTHCOM. Minor short-term adverse direct impacts from an 

increase in construction and personal vehicles along local roads 

during construction.

Long-term minor adverse direct impacts from an increase in 

personal vehicle use by residents of the proposed housing 

development and from use of the new mixed development.

Potential long-term beneficial impact on regional roads as services 

are provided closer to where people live, which would reduce 

overall traffic.

There would be a negligible long-term beneficial impact to regional 

traffic because SOUTHCOM personnel would not need to commute 

through local roads to work.
EXECUTIVE SUMMARY

ES-9

Table ES-2. Summary of Potential Environmental and Socioeconomic Consequences 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Environmental and Socioeconomic Consequences

Resource No Action MILCON Alternative EUL Alternative

Recreation No impact Negligible long-term indirect adverse impacts from the 

increased use of Doral Central Park by new residents of 

housing development.

Minor long-term indirect adverse impacts from the increased use of 

Doral Central Park by new residents of housing development, mixed-use development, and potentially persons outside the area 

patronizing the commercial development.

Utilities

Potable 

Water

No impact Minor short-term adverse direct impacts to potable 

water could occur when proposed buildings are 

connected to utilities.

Negligible to minor adverse long-term direct impacts to 

potable water from increase in demand associated with 

the proposed military housing development.

The EUL Alternative would have additional demand on utilities 

compared to the MILCON Alternative; however, impacts would be 

similar as outlined below due to the regional capacity of supply 

systems and facilities.

Minor short-term direct impacts to potable water could occur when 

proposed buildings are connected to utilities.

Minor adverse long-term direct impacts to potable water from 

increase in demand associated with the proposed military housing 

and EUL developments.

Wastewater No impact Negligible short-term adverse direct impacts to 

wastewater could occur when proposed buildings are 

connected to utilities.

Negligible to minor adverse long-term impacts to 

wastewater from increase in demand associated with the 

proposed military housing development.

Negligible short-term adverse direct impacts to wastewater could 

occur when proposed buildings are connected to utilities.

Minor long-term adverse direct impacts to wastewater from 

increase in demand associated with the proposed military housing 

and EUL developments.

Stormwater No impact Negligible long-term adverse direct impact to 

stormwater system. Use of appropriate BMPs and 

stormwater controls would minimize impacts from 

construction activities. Stormwater controls would be 

designed to minimize post-construction runoff from 

exceeding pre-construction runoff.

Negligible long-term adverse direct impact to stormwater system. Use of appropriate BMPs and stormwater controls would minimize

impacts from construction activities. Stormwater controls would be 

designed to minimize post-construction runoff from exceeding pre- construction runoff.

Energy

Sources

No impact Negligible short-term adverse direct impacts could occur 

when proposed buildings are connected to utilities.

Negligible long-term adverse direct impacts from 

increase in demand associated with the proposed 

military housing development.

Negligible short-term adverse direct impacts could occur when 

proposed buildings are connected to utilities.

Minor long-term adverse direct impact from increase in demand 

associated with the proposed military housing and EUL 

developments.

Solid Waste No impact Minor short-term adverse direct impact from an increase 

in construction debris.

No long-term adverse direct impacts from permanently 

using landfill capacity through the disposal of 

nonrecyclable construction debris and the increase in 

solid waste generated by occupants of the military 

housing development because residents of the housing 

development would be relocating from the county.

Minor short-term adverse direct impact from an increase in 

construction debris.

Minor long-term adverse direct impacts from permanently using 

landfill capacity through the disposal of nonrecyclable construction 

debris and the increase in solid waste generated by occupants of 

the EUL development.
EXECUTIVE SUMMARY

ES-10

Table ES-2. Summary of Potential Environmental and Socioeconomic Consequences 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Environmental and Socioeconomic Consequences

Resource No Action MILCON Alternative EUL Alternative

Visual Resources No impact Moderate short-term adverse direct impacts during 

construction from stockpiles of materials, construction 

vehicles, and partially constructed buildings.

Moderate long-term adverse direct impacts from 

development on a previously undeveloped site. Views 

would be consistent with surrounding area.

Moderate short-term adverse direct impacts during construction 

from stockpiles of materials, construction vehicles, and partially 

constructed buildings.

Moderate long-term adverse direct impacts from development on a 

previously undeveloped site. Views would be consistent with 

surrounding area.

BMP = Best Management Practice

OSHA = Occupational Safety and Health Administration
SECTION 1

1-1

Purpose, Need, and Scope

1.1 Introduction

U.S. Army Garrison-Miami (USAG-Miami) is in Doral, Florida in Miami-Dade County, approximately 3 miles west of 

Miami International Airport (Figure 1-1). A major tenant of USAG-Miami in Doral is U.S. Southern Command 

(SOUTHCOM). USAG-Miami also supports SOUTHCOM’s subordinate commands, U.S. Marine Forces South and 

Special Operations Command South, in Homestead, Florida as well as various other organizations. 

SOUTHCOM is the unified command responsible for force protection of U.S. military resources in Central America, 

South America, and the Caribbean (except U.S. commonwealths, territories, and possessions). SOUTHCOM’s area 

of responsibility encompasses 31 countries and 16 dependencies and areas of special sovereignty. The 

SOUTHCOM mission includes countering transnational crime, counterterrorism, building partner capacity, 

contingency response, and detainee operations (SOUTHCOM, 2019). U.S. Marine Forces, South is the Marine 

Corps component command for SOUTHCOM. Special Operations Command South provides contingency response 

force and plans, prepares for, and conducts special operations in support of SOUTHCOM. 

The number of permanent party military personnel at USAG-Miami is 1,250 and is estimated to be 1,242 in 2025. 

Approximately 75 percent of the USAG-Miami military population works in Doral, Florida (USAG-Miami, 2018). 

There is no military housing on the USAG-Miami cantonment. This creates significant financial, security, and 

quality of life issues for service members and adversely affects mission readiness (USAG-Miami, 2018).

1.2 Purpose and Need

The purpose of the Proposed Action is to provide military housing for USAG-Miami’s housing requirement. This 

includes housing for 50 Key and Essential Family Units and 120 Unaccompanied Enlisted Units within 5 miles/15 

minutes peak traffic commute from SOUTHCOM headquarters in Doral, Florida. This ensures essential personnel 

can walk to the installation and enables mission readiness. The remainder of the housing requirement (120 Family 

Units) should be within 20 miles/60 minutes peak traffic commute from SOUTHCOM headquarters. The need for 

the Proposed Action is to minimize mission interruption during emergency conditions and to improve security, 

increase affordability, and provide cohesion for families and staff. 

There is no military housing on the USAG-Miami cantonment and no space within the cantonment to construct 

military housing. The absence of housing on the installation presents a mission sustainment problem because it 

results in personnel being scattered across the city and county. In the event of an emergency, essential personnel 

may be unable to reach the SOUTHCOM facility to maintain operations because of road closures and traffic. 

The SOUTHCOM housing problem is compounded by the critical shortage of available housing in the local market 

(USAG-Miami, 2018). This makes it challenging for service members to find affordable housing near their place of 

work and requires them to commute from greater distances than they would have to otherwise. Based on a 2018 

Housing Market Analysis, by 2023, USAG-Miami will be short 318 homes (172 Family Housing Units and 146 

Unaccompanied Housing Units) (USAG-Miami, 2018). In accordance with current Army guidance this action would

construct enough units to address 90 percent of the Family Housing shortfall of 155 units and approximately 95

percent of the Unaccompanied Housing shortfall of 140 units. 

The absence of military housing on the USAG-Miami cantonment also makes it difficult to provide the high-level of 

required security for the combatant commander and protection for key and essential (K&E) and mission essential 

personnel. The Proposed Action of constructing a military housing development adjacent to SOUTHCOM facilities 

would improve mission resiliency by providing safe and connected residences within walking distance of the 

installation.
SECTION 1 – PURPOSE, NEED, AND SCOPE

1-2

1.3 Scope

This Environmental Assessment (EA) has been developed in accordance with the National Environmental Policy 

Act of 1969 (NEPA) and implementing regulations found at 40 Code of Federal Regulations (CFR) Parts 1500 

through 1508, and 32 CFR 651. Its purpose is to inform decision makers and the public of the likely environmental 

consequences of the Proposed Action and alternatives, while presenting the rationale used for evaluating and 

determining impacts. Mitigation measures are identified and described where warranted.

This EA identifies, documents, and evaluates the environmental and socioeconomic direct and indirect impacts, 

both temporary and permanent, of construction and routine operation and maintenance of a new housing 

development for USAG-Miami, including the potential for interaction with past, present, and reasonably 

foreseeable future actions that could produce cumulative impacts on resources. An interdisciplinary team of 

environmental scientists, biologists, planners, economists, engineers, archaeologists, historians, and military 

technicians has analyzed the Proposed Action and alternatives considering existing conditions and has identified 

relevant beneficial and adverse effects associated with the action and alternatives. 

This EA also considers the potential impacts of the No Action Alternative, as required by NEPA, to provide a 

benchmark for comparison of the potential impacts of the Proposed Action and the alternatives.

1.3.1 Resources Eliminated from Analysis

The following resource areas have been eliminated from analysis in the EA because there is no potential for 

significant impacts from the Proposed Action. These resource areas will not be discussed further in the EA.

Geology

The City of Doral, located in the southeastern Florida peninsula, is characterized by carbonate sediments of mostly 

soft, oolithic limestone and dolostone. The City of Doral is situated on the geological formation called the Miami 

Limestone, a marine-derived limestone of Pleistocene age. Miami Limestone is porous, and outcrops generally 

display an irregular karst topography. The Miami Limestone is considered part of the Biscayne (shallow) aquifer, 

and is generally less than 40 feet thick (CH2M, 2017). There would be no change to geology or geologic formations 

as a result of the Proposed Action.

Prime Farmland

The Farmland Protection Policy Act of 1981 (FPPA) requires federal agencies to identify and take into account the 

adverse effects of their actions on the preservation of farmland. The FPPA defines prime farmland as “...land that 

has the best combination of physical and chemical characteristics for producing food, feed, fiber, forage, oilseed, 

and other agricultural crops with minimum inputs of fuel, fertilizer, pesticides, and labor, and without intolerable 

soil erosion, as determined by the Secretary. Prime farmland also includes land that possesses the above 

characteristics but is being used currently to produce livestock and timber. It does not include land already in or 

committed to urban development or water storage...” Acquisition or use of farmland by a federal agency for 

national defense purposes is exempted by Section 1547(b) of the Act, 7 United States Code (U.S.C.) § 4208(b). 

Prime farmland does not occur within the proposed project area; therefore, no impacts to prime farmland would 

occur as a result of the Proposed Action.

Environmental Justice and Protection of Children

Populations of low-income residents, minorities, or children near the project area are associated with the nearby 

Doral Terrace Apartment Complex, local schools, and several nearby neighborhoods. Executive Order (EO) 13045 

seeks to protect children from disproportionate environmental health or safety risks that might arise as a result of 

federal policies, programs, activities, and standards. The proposed military housing development would be 

surrounded by a security fence, and access would include a manned access control point. No impacts to 

environmental justice populations or children would occur as a result of the Proposed Action because all 

proposed activities would be within the secure housing development. The Proposed Action would not 

disproportionally impact the surrounding communities.
SECTION 1 – PURPOSE, NEED, AND SCOPE

1-3

1.3.2 Resource Areas Analyzed 

This EA includes an analysis of resource areas that could be impacted by the Proposed Action. These include the 

following, which are discussed in Section 3:

• Land Use

• Soils

• Groundwater

• Surface Water

• Water Quality

• Flood Hazards

• Air Quality

• Noise

• Biological Resources

• Cultural Resources

• Socioeconomic Resources

• Coastal Zone Management

• Safety and Occupational Health

• Hazardous Materials 

• Traffic and Transportation 

• Recreation

• Utilities

• Visual Resources

1.4 Public Involvement

The U.S. Army (Army) invites public participation in the proposed federal action through the NEPA process. 

Consideration of the views and information of all interested persons promotes open communication and enables 

better decision making. All agencies, organizations, and members of the public having a potential interest in the 

Proposed Action, including minority, low-income, disadvantaged, and Native American groups, are urged to 

participate in the decision-making process. Consultation letters will be submitted to the Florida Historic 

Preservation Office, the Miccosukee Tribe of Indians of Florida, and Seminole Tribe of Florida (Appendix A) and 

the Coastal Zone Consistency Determination will be submitted to the Florida State Clearinghouse (Appendix B). 

Responses to the consultation letters, comments from the Florida State Clearinghouse, and documentation of 

follow-on coordination will be included in Appendix A once they have been received. 

Public participation opportunities with respect to this EA and decision making on the Proposed Action were 

guided by 32 CFR Part 651. A Notice of Availability of the Draft EA and Finding of No Significant Impact (FONSI)

(Appendix C) will be published in the Miami Herald. The EA and FONSI will be made available to the public for 

comment for 30 days. 

1.5 Relevant Statutes and Executive Orders

A decision on whether to proceed with the Proposed Action depends on numerous factors such as mission 

requirements, schedule, availability of funding, and environmental considerations. In addressing environmental 

considerations, the Army is guided by relevant statutes (and their implementing regulations) and EOs that 

establish standards and provide guidance on environmental and natural resources management and planning, 

which are listed in the following subsections.
SECTION 1 – PURPOSE, NEED, AND SCOPE

1-4

1.5.1 Federal Regulations

• NEPA (42 United States Code [U.S.C.] 4321-4370)

• Endangered Species Act of 1973 (ESA) (16 U.S.C. 1531-1543)

• Fish and Wildlife Coordination Act (16 U.S.C. 661, et seq.)

• Migratory Bird Treaty Act (MBTA) (16 U.S.C. 701, et seq.)

• Clean Water Act of 1977 and the Water Quality Act of 1987 (33 U.S.C. 1251 et seq., as amended) 

• Energy Policy Act of 2005 (42 U.S.C. § 15801)

• National Energy Conservation Policy Act (42 U.S.C. § 8251)

• Farmland Protection Act of 1981 (7 U.S.C. 4201 et seq., as amended)

• Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 (as amended by 

the Superfund Amendments and Reauthorization Act of 1986) 

• Resource Conservation and Recovery Act (RCRA) of 1976 (42 U.S.C. 6901)

• Toxic Substances Control Act (15 U.S.C. 2601 et seq., as amended)

• National Historic Preservation Act of 1966 (16 U.S.C. 470 et seq., as amended)

• Archaeological Resources Protection Act of 1979 (16 U.S.C. 470)

• Native American Graves Protection and Repatriation Act of 1990 (25 U.S.C. §§ 3001 et seq., as amended)

• American Indian Religious Freedom Act of 1978 (42 U.S.C. § 1996, as amended)

• Clean Air Act (CAA) (42 U.S.C. 7401 et seq., as amended) 

• Noise Control Act of 1972 (42 U.S.C. 4901 - 4918)

• Coastal Zone Management Act (CZMA) (Section 307 and 15 CFR Part 930 subpart C)

1.5.2 Army Regulations

• Army Regulation (AR) 190-13, The Army Physical Security Program

• AR 200-1, Environmental Protection and Enhancement 

• AR 210-20, Installation Master Planning

• AR 385-10, The Army Safety Program

• AR 420-10, Facilities Management

• AR 525-13, Antiterrorism

• Unified Facilities Criteria (UFC) 1-200-02, High Performance and Sustainable Building Requirements, with 

Change 3

• UFC 2-100-01, Master Planning

• UFC 4-010-01, Department of Defense (DoD) Minimum Antiterrorism Standards for Buildings

• UFC 4-020-01, DoD Security Engineering Facilities Planning Manual

• UFC 4-711-01, Family Housing
SECTION 1 – PURPOSE, NEED, AND SCOPE

1-5

• Council on Environmental Quality (CEQ) Regulations for Implementing NEPA (40 CFR Parts 1500-1508)

• Environmental Analysis of Army Actions (32 CFR 651)

• Protection of Historic Properties (36 CFR Part 800)

1.5.3 Executive Orders

• EO 11514, Protection and Enhancement of Environmental Quality, as amended

• EO 11988, Floodplain Management, as amended 

• EO 12088, Federal Compliance with Pollution Control Standards

• EO 12372, Intergovernmental Review of Federal Programs

• EO 12580, Superfund Implementation, as amended

• EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income 

Populations

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

• EO 13175, Consultation and Coordination with Indian Tribal Governments

• EO 13186, Responsibilities of Federal Agencies to Protect Migratory Birds

• EO 13327, Federal Real Property Asset Management

• EO 13834, Efficient Federal Operations

These authorities are addressed in various sections throughout this EA when relevant to particular environmental 

resources and conditions. The full text of the laws, regulations, and EOs is available on the DoD Environment, 

Safety and Occupational Health Network and Information Exchange website at https://www.denix.osd.mil/.

1.6 Organization of the Document

This EA is divided into the following sections and appendices: 

• Section 1 provides background information on USAG-Miami, identifies the purpose of and need for the 

Proposed Action, explains the regulatory agency review and public involvement process, and describes the 

analysis framework. 

• Section 2 defines the Proposed Action, Federal Aviation Administration (FAA) Military Construction (MILCON) 

Alternative, Enhanced Use Lease (EUL) Alternative, and the No Action Alternative and provides the rationale 

for dismissing other alternatives from detailed consideration.

• Section 3 describes existing environmental conditions in the area where the Proposed Action would occur and 

identifies the potential impacts of implementing the Proposed Action. 

• Section 4 summarizes the cumulative impacts of the Proposed Action. 

• Section 5 provides the references cited in development of the EA. 

• Section 6 identifies the preparers of the EA. 

• Section 7 identifies the agencies that received the EA for review. 

• Section 8 identifies persons consulted during preparation of the EA. 

• Appendix A provides a record of correspondence with state and federal agencies and Native American 

organizations. 
SECTION 1 – PURPOSE, NEED, AND SCOPE 

1-6

• Appendix B contains the Coastal Zone Consistency Determination.

• Appendix C contains the Draft FONSI and comments received from the public.

• Appendix D contains Air Quality Emission Estimates and Record of Non-Applicability.

• Appendix E contains special-status species descriptions.
SECTION 1 – PURPOSE, NEED, AND SCOPE 

1-7

1-1. Proposed Project Location
SECTION 1 – PURPOSE, NEED, AND SCOPE 

1-8

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2-1

Description of the Proposed Action and 

Alternatives

This section describes the Proposed Action and alternatives that meet the project purpose and need as described 

in Section 1.2. The MILCON Alternative, EUL Alternative, and the No Action Alternative were selected for detailed 

analysis and are described in Section 2.2. In addition, alternatives considered but not carried forward are described 

in Section 2.3.

2.1 ProposedAction

The Proposed Action is for USAG-Miami to acquire FAA land south of NW 33rd Street across from the SOUTHCOM 

headquarters in Doral, Florida and construct a military housing development on the property. The property houses 

a large FAA radar tower and associated support buildings near its center. No housing or other vertical structures 

would be constructed within the 853-foot radius FAA established antenna standoff area to avoid interference with 

operation of the radar system; however, non-vertical assets such as stormwater retention infrastructure, roads, or 

parking may be located within this radius. Proposed structures between the 853-foot radius and the 1,019-foot 

radius would be compliant with FAA requirements for those designated areas and would not interfere with 

operation of the radar. The Proposed Action would meet most of the USAG-Miami 2020 military housing shortfalls 

described in the Purpose and Need (Section 1.2).

2.1.1 Construction Components

Proposed construction of the housing development would include construction of buildings with masonry block 

and stucco exterior wall and concrete tile roof. Family housing would have living areas, kitchens, bathrooms, 

bedrooms, storage, double-car garages, and private entrances. Unaccompanied housing units would have living 

and sleeping areas, baths, and storage. All housing would meet requirements for soundproofing, and all General 

Officers’ quarters would meet Sensitive Compartmented Information Facility requirements. Construction of 

supporting facilities would include the following site work: earthwork consisting of 3 feet of fill, utilities and 

connections, lighting, paving, parking, walks, curbs and gutters, storm drainage, information systems connectivity, 

pedestrian walkway beneath NW 33rd Street, and landscaping and signage. Heating and air conditioning would be 

provided by self-contained systems, and residential smoke detectors would be provided.

Measures in accordance with the DoD Minimum Antiterrorism for Buildings standards and protection for high-risk 

personnel would be provided. Accessibility for individuals with disabilities would be provided. Comprehensive 

building-related and furnishings-related interior design services would be required. The project would comply with 

the Army Standard for Family Housing and UFC 4-711-01. Design and construction would include requirements of 

current Sustainable Design and Development Policy Update (Environmental and Energy Performance). Facilities 

will be designed to a minimum life of 50 years in accordance with DoD's UFC 1-200-02, including energy 

efficiencies, building envelope, and integrated building systems performance. Antiterrorism measures shall be 

provided in accordance with UFC 4-020-01.

The Proposed Action includes the following construction components:

• Child Development Center and Associated Parking: The child development center would be a 15,000-squarefoot, single-level building with associated paved parking containing 47 spaces.

• Community Center and Associated Parking: The community center would be a 15,000-square-foot building 

with optional housing located on the second floor and associated paved parking containing 36 spaces.

• Multi Grade Family Housing: Family housing would include 155 total homes.

• Unaccompanied Housing: Unaccompanied housing would include 140 total units. 
SECTION 2 – DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES

2-2

• Multipurpose Amenities: Multipurpose amenities would include playgrounds (four tot lots and four play lots), 

two open fields, two tennis courts, two basketball courts, two dog parks, three picnic areas, a bicycle/walking 

path, a community garden plot, 18 bicycle racks, 36 benches, and a personal vehicle wash rack. 

• Access Control Point: An access control point for the housing development would include an 880-square-foot 

gatehouse and a 1,600-square-foot search area canopy for trucks.

• Guardhouse and Pedestrian Walkway: A connector road between the housing development and the 

SOUTHCOM headquarters access control point at Gate 1 would be constructed. This would include a 110-

square-foot guardhouse and a 26,500-square-foot, below grade pedestrian walkway with stairwell and landing. 

Construction of the connector road would require elevating a portion of NW 33rd Street to allow the 

underpass.

• Security Perimeter: New security fencing would be installed around the perimeter of the housing 

development. 

• Stormwater Drainage: Stormwater drainage would include two water retaining basins—one would be up to 

14,500 cubic feet and the other up to 21,600 cubic feet in size—and 24,800 linear feet of stormwater piping.

• Site Improvements: Site clearing and grading for site improvements (such as curbs, gutters, sidewalks, and 

landscaping) would occur over 37.5 acres. Three feet of fill would be added to the site totaling 181,500 cubic 

yards. Landscaping and planting would require approximately 5,000 cubic yards of topsoil.

• Utilities: Utility construction would include 42,000 linear feet of water distribution lines, 36,000 linear feet of 

sewer lines, and 14,700 linear feet of underground electrical lines. 

• Paving, Walks, Curbs, and Gutters: There would be up to 80,600 square yards of asphalt road paving, 4,800 

square yards of concrete pavement, 100,000 square yards of sidewalks and walkways, 40,000 linear feet of 

precast concrete curbs, and gutters.

2.1.2 Operations Components

Operations would include routine maintenance of buildings and grounds.

• Security: The housing area would be secured from unauthorized entry and the gatehouse would be manned.

• Building Maintenance: Structures in the housing development would receive regular interior and exterior 

maintenance to prevent deterioration. 

• Landscape Maintenance: Landscape maintenance would include mowing, pruning, and weed removal around 

buildings to maintain lawns and ornamental plantings and to keep walkways in good condition.

• Utilities Maintenance: Water, sewer, power, and telecommunications utilities would be maintained to prevent 

interruptions of service. This maintenance may include excavation to expose buried utility lines to make 

repairs.

2.2 Alternatives

2.2.1 Alternative 1 –MILCON Alternative 

In the MILCON Alternative, USAG-Miami would use congressionally approved funds to acquire some or all of the

approximately 160-acre FAA parcel and pay for the construction, operation, management, and maintenance of 

service member housing, including site improvements, on up to 75 acres of the property (Figure 2-1). The MILCON 

Alternative would consist of constructing and operating a housing development as described in the Proposed 

Action (Section 2.1). Under this alternative, no building structures would be built on the central portion (52.4 

acres) of the parcel as not to interfere with radar tower operations; however, non-vertical assets such as 

stormwater retention infrastructure, roads, or parking may be located within this radius.
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2-3

2.2.2 Alternative 2 –EULAlternative

In the EUL Alternative, USAG-Miami would obtain an EUL agreement with a private developer to construct and 

operate a housing development on the approximately 160-acre FAA parcel (Figure 2-2). This alternative would 

include constructing and operating a housing development as described in the Proposed Action (Section 2.1) on up 

to 75 acres of the northern portion of FAA parcel. In addition, up to 32.5 acres of the southern portion of the FAA 

parcel would be offered to a developer for a mixed-use development in exchange for funding the construction of 

the military housing, for a total area of development up to 107.5 acres, including site improvements. The southern 

development would include up to 302,000 square feet of retail space below two levels of 167 market rate 

apartments and would include up to 806 parking spaces. Under this alternative, no building structures would be 

built on the central portion (52.4 acres) of the parcel as not to interfere with radar tower operations; however, 

non-vertical assets such as stormwater retention infrastructure, roads, or parking may be located within this 

radius.
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2-4

2.2.3 Alternative 3–No Action Alternative

Under the No Action Alternative, USAG-Miami would not acquire the FAA parcel directly adjacent to the 

SOUTHCOM headquarters in Doral, Florida and would not construct a military housing development. Service 

members would continue to search for affordable housing in the local economy and be scattered across the city 

and county. This would continue to create an undue financial burden on many service members as they seek 

suitable quarters and would continue to adversely impact mission readiness for USAG-Miami and SOUTHCOM. 

Essential personnel would continue to be unable to quickly reach the SOUTHCOM headquarters facility to maintain 

operations during emergencies as a result of possible road closures and traffic. Higher-level personnel living offsite 

would not be provided with required additional security for personal protection. 

Under the No Action Alternative, revisiting the option of acquiring the FAA parcel a few years from now may not 

be a possibility. FAA is systematically updating traffic control systems, and the large satellite dish at the FAA parcel

may become obsolete. If FAA opts to dispose of this property and the Army is not in the position to acquire it, an 

opportunity to enhance the SOUTHCOM mission and improve service members’ quality of life would be lost.

The No Action Alternative would not address the purpose and need for the Proposed Action. The No Action 

Alternative is included for analysis as required by NEPA and serves as reference for comparison of potential effects 

of the Proposed Action.
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2-5

2.3 Alternatives Dismissed from Consideration

USAG-Miami developed the Proposed Action and alternatives based on consideration of mission requirements, 

security requirements, environmental constraints, and mission efficiency. Five alternatives for meeting housing 

shortfalls at USAG-Miami were evaluated in a cost-benefit analysis; three of them were dismissed (USAG-Miami, 

2018). Alternatives dismissed from further consideration are described below.

2.3.1 Alternative 4–Privatized Housing on FAA Parcel

Under Alternative 4, privatized housing would be constructed on the 160-acre FAA parcel. The Residential 

Communities Initiative (RCI), the most common form of housing privatization, has been widely used on military 

bases; however, the authority to use this model has recently expired. If the authority could be restarted, this 

model leverages the Basic Allowance for Housing to access the private capital market to fund construction and 

maintenance without congressionally appropriated funds. 

Alternative 4 requires a new privatization authority and needs an Army-level feasibility review. Because of limited

scope and financial uncertainties, this alternative might be unattractive to an RCI partner. For economic viability, 

civilian occupancy of the housing development may eventually be required. Allowing civilians in the secure 

perimeter could jeopardize service members’ safety. Security also would be compromised if other government 

personnel were permitted to lease units. As a result of the aforementioned factors, Alternative 4 was dismissed 

from further consideration.

2.3.2 Alternative 5–MILCON Family Housing Project near Homestead Air Reserve Base

Under Alternative 5, MILCON funds would be used to construct a housing development on other Real Property 

near Homestead Air Reserve Base, approximately 26 miles south of USAG-Miami. The land of the former 

Homestead Air Force Base was transferred to the Air Force Reserve and to Miami-Dade County following closure of 

the Air Force Base. USAG-Miami currently manages the operational facilities of Special Operations Command 

South on an 84.2-acre leased site owned by Miami-Dade County. USAG-Miami was directed by the Army to 

evaluate building on land owned by Miami-Dade County. The cost to acquire land, if available, would be an 

estimated $10,147,966.

Constructing housing in Homestead would exacerbate rather than solve most of the issues SOUTHCOM is trying to 

resolve. Availability of suitable land for this project is assumed; however, no suitable contiguous tracts of land are 

available that meet the requirement. Furthermore, the drive time between the two locations averages between 40 

and 45 minutes without traffic issues, and all major routes require tolls of approximately $5 per day for the drive. 

K&E personnel could not be assigned in Doral and housed in Homestead. Homestead suffers from a lack of 

acceptable childcare, schools, and healthcare (USAG-Miami, 2018). As a result of the aforementioned factors, 

Alternative 5 was dismissed from further consideration.

2.3.3 Alternative 6–Expanded Leasing (in Doral Only)

Alternative 6 is similar to the No Action Alternative but would require the housing office to lease, rent, or buy real 

estate in the corporate limits of Doral only and assign it to personnel. This variation on the No Action Alternative

limits many of the negative aspects of the No Action Alternative. Additional housing office personnel would be 

required to verify that homes meet Army requirements and to maintain the pool of residences. 

This alternative has the highest cost and does not improve service member security. A large increase in the 

Directorate of Public Works Housing Office staff would be required and service members would face high upfront 

costs in the Doral rental market. Additionally, personnel could encounter traffic and road closures that could delay 

their ability to quickly reach the installation in an emergency. This alternative was dismissed from further 

consideration because it does not meet the purpose and need of the Proposed Action.
SECTION 3

3-1

Affected Environment and Consequences

3.1 Introduction

This section describes the existing environmental and socioeconomic conditions that could be affected by 

implementing the Proposed Action, as well as the potential environmental and socioeconomic impacts of 

implementing the Proposed Action Alternatives and the No Action Alternative. 

This section provides information to serve as a baseline from which to identify and evaluate environmental and 

socioeconomic changes likely to result from implementation of the Proposed Action. Baseline conditions are

current conditions. 

In compliance with NEPA, CEQ guidelines, and 32 CFR Part 651, et seq., the description of the affected 

environment focuses on those resources and conditions potentially subject to impacts. These include land use, 

soils, groundwater, surface water, water quality, flood hazards, air quality, noise, biological resources, cultural 

resources, socioeconomics, coastal zone management, safety and occupational health, hazardous materials

transportation, recreation, utilities, and visual resources.

Following the description of the components of the affected environment, this section presents the analysis of the 

direct and indirect environmental and socioeconomic effects that would likely occur with the Proposed Action and 

identifies any adverse environmental effects that could not be avoided through project design. Potential 

cumulative impacts are discussed in Section 4.

3.1.1 Direct versus Indirect Effects 

The terms “effect” and “impact” are synonymous as used in this EA. Effects may be beneficial or adverse and may 

apply to the full range of natural, aesthetic, historic, cultural, and economic resources within the proposed project 

area and also within the surrounding area. Definitions and examples of direct and indirect impacts as used in this 

document are as follows: 

• Direct Impact. A direct impact is one that would be caused by implementing an alternative and that would 

occur at the same time and place. 

• Indirect Impact. An indirect impact is one that would be caused by implementing an alternative that would 

occur later in time or would be farther removed in distance but would still be a reasonably foreseeable 

outcome of the action. Indirect impacts may include induced changes in the pattern of land use, population 

density, or growth rate, and indirect effects to air, water, and other natural resources and social systems. 

• Relationship between Direct versus Indirect Impacts. For direct impacts to occur, a resource must be 

present. For example, if highly erodible soils were disturbed as a direct result of the use of heavy equipment 

during construction of a home, there could be a direct effect on soils resulting from erosion. This could 

indirectly affect water quality if stormwater runoff containing sediment from the construction site were to 

enter a stream.

3.1.2 Short-term versus Long-term Effects

Effects are also expressed in terms of duration. The duration of short-term impacts is 1 year or less from 

completion of construction. For example, the construction of a building would likely expose soil in the immediate 

area of construction. However, this effect would be considered short term because it would be expected that 

vegetation would re-establish on the disturbed area within a year of the disturbance. Long-term impacts are 

described as lasting beyond 1 year. Long-term impacts can continue in perpetuity, in which case they would also 

be described as permanent. 
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3.1.3 Intensity of Effects

The magnitude of effects of an action must be considered regardless of whether the effects are adverse or 

beneficial. The following terms are used to describe the magnitude of impacts:

• No Impact: The action does not cause a change. 

• Negligible: The impact is at the lowest level of detection and is discountable or hardly noticeable.

• Minor: The impact is slight but detectable.

• Moderate: The impact is readily apparent.

• Major: The impact is severely adverse or exceptionally beneficial.

Impacts ranging from negligible to moderate would be less than significant, while major impacts would be 

significant.

3.1.4 Significance 

In accordance with CEQ regulations and implementing guidance, impacts are also evaluated in terms of whether 

they are significant. Both short-term and long-term effects are relevant to the consideration of significance. 

“Significance,” as defined in the CEQ regulations for implementing NEPA at 40 CFR 1508.27, requires 

consideration of context and intensity. “Intensity” refers to the severity of the impact and describes the degree to 

which an impact occurs on a resource element (40 CFR 1508.27(b)).

“Context” requires that significance be considered with regard to society, the affected region, affected interests, 

and the locality (40 CFR 1508.27(a)). The scale of consideration for context varies with the setting and magnitude 

of the action. For instance, a small, site-specific action is best evaluated relative to the location rather than to the 

entire world. 

3.1.5 Mitigation

The alternatives considered in this EA could have environmental and socioeconomic impacts resulting from their

implementation that would require mitigation. Where potentially significant adverse impacts are identified, 

measures that would be implemented to mitigate for the magnitude of impacts are discussed. Potential 

mitigation actions, as defined by 40 CFR § 1508.20, could include: 

• Avoiding the impact altogether by not taking a certain action or parts of an action.

• Minimizing the impact by limiting the degree or magnitude of the action and its implementation.

• Rectifying an impact by repairing, rehabilitating, or restoring the affected environment.

• Reducing or eliminating an impact over time by preservation and maintenance operations during the life of 

the action.

• Compensating for an impact by replacing or providing substitute resources or environments.

Where no significant adverse impacts are identified, rectifying or compensatory mitigation measures are not 

proposed. Absent significant adverse impacts, the Army would implement Best Management Practices (BMPs) 

and project design features to avoid impacts or minimize unavoidable impacts that are less than significant.

3.2 Land Use

3.2.1 Affected Environment

The FAA parcel where the proposed housing development would be constructed is federal government land and 

has been operated by the FAA for more than 70 years. The approximately 160-acre FAA-owned parcel is located 
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

3-3

south of NW 33rd Street across from the current SOUTHCOM headquarters, within the municipal limits of the City 

of Doral. The FAA parcel is bound to the north by NW 33rd Street, east by NW 92nd Avenue, south by NW 25th

Street, and to the west by NW 97th Avenue (Figure 1-1). The property contains an FAA Remote Center Air to 

Ground facility that includes a communications (VORTAC) dish and several small ancillary outbuildings near the 

center of the site. Additionally, there is a 2.7-acre parking lot used by the Miami-Dade Police Department in the 

southeastern segment of the parcel fronting NW 92nd Avenue. There is an 853-foot radius around the VORTAC 

dish that cannot be developed with any vertical improvements while the dish is in use. The City of Doral has 

designated the northern half of the property as a General Use District and the southern half of the property as an 

Industrial Commercial District (City of Doral, 2019a).

The FAA parcel is currently used as a pasture for cattle grazing and in the recent past, portions of the parcel also 

were used for floriculture (CH2M, 2017). Pasture in the local area is limited to one other plot approximately 1 mile 

to the west that is of similar size to the FAA parcel. The next closest pasture is south of Miami, between 

Homestead and the Everglades.

To the east of the FAA parcel is the Miami-Dade County police station (Station 3) and Doral Central Park (J.C. 

Bermudez Park), an 82-acre recreation park. Residential housing is located to the west of the FAA parcel. Various 

industrial buildings and shops are located to the south of the FAA parcel. 

3.2.2 Environmental Consequences

3.2.2.1 MILCON Alternative 

Under the MILCON Alternative, USAG-Miami would acquire some or all of the FAA parcel and the FAA would 

continue to use the VORTAC dish and the 52.4-acre clear zone around it. The land would remain federal 

government land. The land use designation would not change as the general use category includes residential 

usage (City of Doral, 2019a). Up to 75 acres of pasture would be converted to residential land for construction of a 

housing development. Because the change in use would be consistent with the land use designation, any longterm direct effects on land use would be negligible. The economic effects of the loss of pasture/grazing are 

discussed in Section 3.12.

No long-term or short-term indirect adverse impacts to land use would be expected because no population 

change would occur, as the residents would be relocating from within the area.

3.2.2.2 EUL Alternative 

Under the EUL Alternative, USAG-Miami would acquire some or all of the FAA parcel. Under the EUL Alternative, 

the 52.4-acre clear zone around the VORTAC dish would remain under FAA control. Up to 107.5 acres of pasture 

would be converted to housing and mixed-use development: A housing development would be constructed on up 

to 75 acres of the northern portion of the parcel and a mixed-use residential and commercial development would 

be constructed on 32.5 acres in the southern portion of the property. The land use designation would not change 

as the general use category includes residential usage and the industrial commercial-use category includes 

residential usage, such as multi-family condominium/apartments or work-live residential units as well as 

restaurants, retail and services (City of Doral, 2019a). Because the change in use would be consistent with the 

land use designation, any long-term direct effects on land use would be negligible. The economic effects of the 

loss of pasture/grazing are discussed in Section 3.12.

No adverse indirect impacts to land use would be expected because the surrounding area is already developed.

The commercial component of the EUL area would serve the local area and would not result in additional changes 

to land use.

3.2.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.2.1 

would continue. There would be no impacts to land use from the Proposed Action.
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3-4

3.3 Soils

3.3.1 Affected Environment

Soil in the proposed project area consists of Hallandale fine sand 0 to 2 percent slope. This soil type is derived 

from sandy marine sediments over a limestone and typically occurs on low broad flats, flatwoods, sloughs, and in 

depressions on marine terraces. This soil is poorly drained with rapid permeability (NRCS, 2019). The depth to 

water table is 6 to 18 inches below surface. The typical profile of Hallandale is very dark gray fine sand between 0 

and 4 inches, light brownish gray fine sand between 4 and 16 inches, and soft porous weathered bedrock 

between 16 and 20 inches (CH2M, 2017).

The Hallandale fine sand is considered hydric soil, one of three requirements to be a wetland. This soil is not used 

for cultivation due to its poorly drained soils and very high ability to transmit water. Hallandale fine sand soils 

have a low susceptibility to erosion from precipitation and are highly susceptible to wind erosion. Urban

development is a common use for Hallandale fine sands (CH2M, 2017). Within the area of the FAA parcel grazed 

by cattle, soils tend to be more compacted directly around where feed troughs are placed.

3.3.2 Environmental Consequences

3.3.2.1 MILCON Alternative 

Under the MILCON Alternative, adverse direct impacts to soils from site preparation and construction on up to 75 

acres would be long term and moderate. Adverse direct impacts to soils could include compaction from heavy 

equipment during earth-moving activities. Disturbed areas would be kept to the minimum required to complete 

the work and would be confined within site boundaries. Effective sedimentation and erosion control procedures 

and BMPs would be used during construction to minimize erosion of surrounding soils due to soil/ground 

disturbance. Appropriate BMPs would be selected based on site-specific conditions and could include, but would 

not be limited to:

• Sediment barriers (silt fence or straw wattles)

• Temporary detention basins

• Mulching of exposed soils

• Geotextile slope stabilization

• Prompt revegetation of disturbed areas

The potential for temporary impacts to water quality are discussed in Section 3.6.2. 

Grading plans for facilities and roadways would be prepared to identify how sites would be graded, how drainage 

patterns would be directed, and how runoff velocities would affect receiving waters. The grading plans also would 

provide information regarding when earthwork would start and stop, establish the degree and length of finished 

slopes, and specify where and how excess material would be disposed of or where borrow materials would be 

obtained if needed. Berms, diversions, and other stormwater practices that require excavation and filling also 

would be incorporated into grading plans. Erosion and sediment control and stormwater management goals 

would be considered in the grading plans. Grading crews would be supervised to ensure that the plans are 

implemented as intended.

Under the MILCON Alternative, short-term indirect adverse impacts to soils could result from increased erosion 

outside the immediate construction area due to site runoff. The construction BMPs discussed above would 

minimize the potential for indirect impacts to soils. Runoff to the north, east, and west would be to roadways and 

the stormwater system and would not encounter soils. Runoff to the south would cross the antenna area and 

potentially the more southern part of the FAA parcel before entering the canal. Any short-term indirect adverse 

impacts to soils from construction runoff would be limited to the southern portion of the FAA parcel and would 

likely be negligible.
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3-5

Approximately 3 feet of compacted fill would be added to the ground surface to bring it up to an acceptable 

developable level. Fills constructed above the natural ground surface increase the load on underlying soil and may 

result in settlement. However, due to the shallow depth of bedrock, and proper compaction of fill prior to 

construction, any settling would be negligible.

Stormwater runoff resulting from increased impervious surface area also could contribute to limited soil erosion. 

Site-specific measures would minimize transport of soils. Contractors would be required to implement measures 

consistent with the Best Management Practices for South Florida Urban Stormwater Management Systems

(SFWMD, 2002). Implementation of the BMPs described for direct impacts would minimize the potential for 

indirect impacts to offsite soils from stormwater runoff. Only minor long-term indirect adverse impacts to soils 

would be expected due to increased impervious area.

3.3.2.2 EUL Alternative 

Under the EUL Alternative, the types of impacts to soils described for the MILCON Alternative (Section 3.3.2.1) 

would occur over a larger area, 107.5 acres. The EUL Alternative would have a greater impact on soils compared 

to the MILCON Alternative, not only from a larger development but also a longer construction duration. However, 

with implementation of erosion and sedimentation controls and BMPs, the long-term direct adverse impacts are 

expected to be moderate. Indirect impacts would be less than that for the MILCON Alternative, because there 

would be less potential to affect offsite soils because only soils in the antenna area would be subject to potential 

stormwater runoff. Any long-term indirect adverse impacts are expected to be negligible.

3.3.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.3.1 

would continue. There would be no impacts to soils from the Proposed Action.

3.4 Groundwater

3.4.1 Affected Environment

The groundwater in southern Florida is contained in two distinct aquifer systems: the Biscayne aquifer and the 

Floridan aquifer. The Biscayne aquifer is relatively shallow (within 1 to 5 feet of land surface) and unconfined with 

a thickness ranging from approximately 80 to 120 feet. The average transmissivity has been estimated to be 5 

million gallons per day per foot. Recharge to the Biscayne aquifer is derived from rainfall, irrigation runoff, surface 

water imported by canals, urban runoff, and groundwater inflow. Average recharge is approximately 38 inches 

per year. The typical well in this aquifer system yields 537 million gallons per day in Miami-Dade County. The 

Biscayne aquifer covers more than 4,000 square miles in southeastern Florida, supplies water to more than 5 

million residents in Miami-Dade, Broward, and southern Palm Beach counties, and is the most intensely used 

water source in Florida (SFWMD, 2019). The Floridan aquifer is deep and confined and has an approximate 

thickness of 2,800 feet. The Floridan aquifer underlies approximately 100,000 square miles in southern Alabama,

southeastern Georgia, southern South Carolina, and all of Florida and provides drinking water to 10 million people

(Stewart, 1980). The typical well in this aquifer system yields 3.68 million gallons per day in Miami-Dade County 

(CH2M, 2017).

The proposed project area is located in the east-central portion of the Biscayne aquifer and the southeastern end 

of the Floridan aquifer. Groundwater flow direction was determined to be to the southeast for the FAA parcel and

surrounding areas based on regional groundwater elevation contour maps. The North Line Canal is south of and 

adjacent to the subject property, and it is likely groundwater flows into the canal (CH2M, 2017).

A Phase I Environmental Site Assessment of land east of the subject property and an EA developed for the land 

north of the subject property found no recognized environmental conditions that may contaminate groundwater 

(CH2M, 2017).
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3.4.2 Environmental Consequences

3.4.2.1 MILCON Alternative 

The MILCON Alternative would have no direct impacts on groundwater. Construction activities would not require 

excavation to the depth of groundwater and no groundwater use would occur onsite.

Stormwater runoff during construction could interact with groundwater recharge zones of the surficial Biscayne 

aquifer. A stormwater permit from the South Florida Water Management District (SFWMD) would be obtained 

prior to construction activities. During construction, appropriate BMPs would be implemented to reduce 

pollutants in stormwater discharges from construction sites (SFWMD, 2002). BMPs that would be implemented 

may include, but would not be limited to:

• Minimize soil exposure through organized scheduling of grading and construction activities.

• Build construction entrances to minimize mud on roadways. Install sediment trapping structures such as silt 

traps, sediment basins, filter fabric, perimeter dikes, and inlet protection.

• Construct retention and detention systems. Stabilize all denuded areas within 3 days after final grading; 

disturbed areas that are inactive and will be exposed to rain for 30 days or more should be temporarily 

stabilized. Stabilization techniques include mulches, vegetation and sod, and chemical applications.

• Implement turf and landscape management.

• Retain existing vegetation whenever feasible.

• Control runoff by diverting stormwater away from stripped areas or newly seeded slopes; minimize the length 

and steepness of slopes; and install check dams, level spreaders, and outlet protection to minimize erosion.

The Biscayne aquifer supplies water for approximately 5 million people in south Florida and using appropriate 

BMPs, negligible long-term indirect adverse impacts to groundwater would be expected as a result of construction 

and operation activities due to the size of the aquifer. Use of groundwater for drinking water by permanent 

residents in military housing would result in negligible long-term indirect adverse impacts on the Biscayne aquifer

from an increase in demand because the demand would be relocated from within the region. The increase in 

impervious surfaces associated with the new development would have no more than a negligible long-term 

indirect adverse impact on recharge rates of the aquifer, given the relatively small size of the development 

(75 acres) compared with the size of the aquifer (4,000 square miles).

3.4.2.2 EUL Alternative 

Under the EUL Alternative, the impacts to groundwater described for the MILCON Alternative (Section 3.4.2.1)

would occur over a larger area, up to 107.5 acres. In addition, the construction associated with the mixed-use 

development could increase the duration and area of construction; however, long-term indirect adverse impacts 

from construction would still be negligible with the implementation of BMPs. There would be a minor increase in 

use of groundwater for drinking water by tenants of the mixed-use development, assuming that not all tenants 

would come from within the region. The EUL Alternative would have a greater impact on groundwater compared 

to the MILCON Alternative, due to the larger development, including higher usage tenants such as restaurants,

and the potential relocation of people from outside the region due to the development. However, the long-term 

indirect adverse impacts to the Biscayne aquifer from this increase in groundwater usage would still be negligible 

considering the small size of the development (107.5 acres) and increase in demand relative to the size of the 

aquifer, 4,000 square miles, and the number of people served by the aquifer at present, approximately 5 million 

people.
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3.4.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.4.1 

would continue. There would be no impacts to groundwater from the Proposed Action.

3.5 Surface Water

3.5.1 Affected Environment

The proposed project area does not contain any permanent pits, ponds, lagoons, or other water bodies. The 

National Wetland Inventory map revealed no wetlands are present within the proposed project area. The North 

Line Canal, a riverine used to remove stormwater runoff from the subject property and adjacent properties, is 

located south of and adjacent to the FAA parcel (CH2M, 2017).

3.5.2 Environmental Consequences

3.5.2.1 MILCON Alternative 

The MILCON Alternative proposed construction would not occur within a surface water resource. However, during 

construction activities, potential adverse short-term direct impacts to surface water quality and hydrogeological 

resources could occur as a result of spills. This risk would be minimized by practicing good housekeeping, such as 

properly storing materials and fueling and maintaining construction equipment offsite or in designated areas with 

appropriate control and containment. A stormwater permit from SFWMD would be obtained prior to construction 

activities. During construction, appropriate BMPs would be implemented to reduce pollutants in stormwater 

discharges from construction sites (SFWMD, 2002). BMPs that would be implemented may include, but would not 

be limited to, those mentioned in Section 3.4.2.1.

Therefore, no more than negligible short-term adverse direct impacts to surface water resources would be 

expected.

Implementation of the BMPs described for direct impacts would minimize the potential for indirect impacts to 

water quality from stormwater runoff and sedimentation. Post-construction stormwater controls would be 

implemented to minimize an increase in the volume of offsite stormwater runoff from an increase in impervious 

area (approximately 50 acres). These stormwater controls would include water retaining basins and stormwater 

piping. No long-term adverse indirect impacts to offsite surface waters would be expected unless storms exceed 

the design storm for the stormwater controls. Storms that exceed the design storm for the stormwater system 

would result in runoff greater than current conditions. Such storm events would be infrequent and associated 

runoff would be diluted due to the larger volume of rainwater; no more than negligible long-term adverse direct 

effects to surface waters would be expected.

3.5.2.2 EUL Alternative 

Under the EUL Alternative, the types of impacts to surface water described for the MILCON Alternative (Section 

3.5.2.1) would occur over a larger area, 107.5 acres. In addition, the construction associated with the mixed-use 

development could increase the duration and area of construction-related impacts. The EUL development would 

comply with regulations for construction and post-construction stormwater management. The EUL Alternative 

would have a greater potential to impact surface waters compared to the MILCON Alternative, not only from a 

larger development (approximately 82 acres of impervious surface, approximately 64 percent greater impervious 

area) but also the longer construction duration resulting in minor short-term direct impacts to surface water 

resources from construction activities. However, with implementation of BMPs, the long-term adverse indirect 

impacts to surface water are expected to be negligible unless storms exceed the design storm for the stormwater 

controls. Storms that exceed the design storm for the stormwater system would result in runoff greater than 

current conditions. Such storm events would be infrequent and associated runoff would be diluted due to the 

larger volume of rainwater; minor to moderate long-term adverse direct effects to surface waters would be 

expected. 
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3.5.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.5.1 

would continue. There would be no impacts to surface water from the Proposed Action.

3.6 Water Quality

3.6.1 Affected Environment

The Biscayne aquifer is the primary drinking water source for Miami-Dade County. Miami-Dade Water and Sewer 

Department (WASD) supplies potable drinking water to the area through county supply lines (CH2M, 2017). Based 

on 2018 water quality data, 21 parameters, including microbiological contaminants, stage 2 disinfection 

byproducts, disinfectants, inorganic contaminants, and radioactive contaminants, were detected in Miami-Dade 

County’s water during the reporting period. All parameters were below the maximum contaminant levels allowed 

(Miami-Dade County, 2018).

Grazing cattle on the FAA parcel may have a negative effect on water quality in the local area. Animal wastes may

be transported to the canal system during and following precipitation events, increasing organic loading of nearby 

surface waters. 

3.6.2 Environmental Consequences

3.6.2.1 MILCON Alternative 

Under the MILCON Alternative, no more than negligible long-term adverse direct impacts to water quality would 

be expected from construction and operation of the housing project. During construction, stormwater 

management regulations and appropriate BMPs would be implemented to reduce pollutants in stormwater 

discharges from construction sites (SFWMD, 2002). BMPs that would be implemented may include, but would not 

be limited to:

• Site grading to minimize runoff 

• Construction entrances to minimize mud on roadways

• Check dams and silt fences to decrease water flow and allow sediment to settle onsite

• Sediment basins and filter berms to remove sediment

• Mulching to stabilize disturbed soils

• Permanent reseeding of disturbed soils 

Implementation of BMPs would minimize the potential for adverse impacts from stormwater runoff and 

sedimentation. Post-construction stormwater controls would be implemented to minimize adverse impacts to 

water quality offsite caused by an increase in impervious area, approximately 50 acres. Due to the 

implementation of BMPs and the post-construction stormwater controls negligible long-term adverse direct 

impacts to water quality would be expected.

There would be long-term beneficial direct impacts to the organic loading of nearby surface waters as a result of 

removal of grazing animals from the FAA parcel.

3.6.2.2 EUL Alternative 

Under the EUL Alternative, the types of impacts to water quality described for the MILCON Alternative (Section 

3.6.2.1) would occur over a larger area, 107.5 acres. In addition, the construction associated with the mixed-use 

development could increase the duration and area of construction-related impacts. The EUL Alternative would 

have a greater impact on water quality compared to the MILCON Alternative, not only from the larger 

development, which includes approximately 82 acres of impervious surface, but also the longer construction 

duration. However, the EUL development would also comply with regulations for construction and postconstruction stormwater management, and with implementation of BMPs and post-construction stormwater 

controls, the long-term adverse impacts to water quality are expected to be negligible.
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There would be long-term beneficial direct impacts to the organic loading of nearby surface waters with the 

removal of grazing animals from the FAA parcel.

3.6.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.6.1 

would continue, including the potential for animal waste from grazing cattle to contribute to organic loading of 

nearby surface waters.

3.7 Flood Hazards

3.7.1 Affected Environment

The City of Doral is flat, has virtually no topographical relief and is proximate to the coast. Variations in relief 

usually result from construction activities. Elevations for the City of Doral average 3.3 feet above mean sea level 

(amsl) and the proposed project area has a ground elevation of 5 feet amsl (CH2M, 2017). The Base Flood 

Elevation for the proposed project area is 6 feet amsl (FEMA, 2009) which means the parcel, at the existing 

elevation of 5 feet amsl, is prone to flooding to a depth of 1 foot. According to the Federal Emergency 

Management Agency’s (FEMA) Flood Insurance Rate Map (FIRM), the proposed project area is located within a 

Special Flood Hazard Area (Zone AH [flood depths of 1 to 3 feet typically from ponding and not within a 

floodplain]) (FEMA, 2009). A Special Flood Hazard Area is the area subject to inundation by a flood that has a 1

percent or greater chance of being equaled or exceeded during any given year.

3.7.2 Environmental Consequences

3.7.2.1 MILCON Alternative 

Under the MILCON Alternative, the structures would be placed on fill material above the Base Flood Elevation. 

Approximately 3 feet of fill would be added to the proposed project area to raise the ground approximately 2 feet 

above the Base Flood Elevation. This would reduce the risk of flooding at the site and bring the site up to an 

acceptable development level. USAG-Miami would submit a request to FEMA to reassess and revise the FIRM to 

indicate that the filled land is outside of the Special Flood Hazard Area. Because the flood hazard derives from 

ponding and the threat of surge associated with storm events and is not associated with conveyance or volume of 

streamflow, and because post-construction stormwater controls would maintain pre-development run-off rates

and volumes, there would be no increased risk of flooding for other properties. Any long-term adverse direct 

impacts to the flood hazard area are expected to be minor. 

Post-construction stormwater controls would be implemented to minimize an increase in the volume of offsite 

stormwater runoff from an increase in impervious area. There would be less than significant long-term adverse 

indirect impacts from an increase in impervious surfaces to the flood hazard area under the MILCON Alternative

because the stormwater controls would minimize runoff increase and because the project area would be less than 

0.1 percent of the surrounding area, which would result in less than 0.01 inch in rise of floodwater in the region.

3.7.2.2 EUL Alternative 

Under the EUL Alternative, the impacts to flood hazards described for the MILCON Alternative (Section 3.7.2.1) 

would occur over a larger area, 107.5 acres. The area to add the 3 feet of fill would be greater due to the 

increased area for the EUL component, but there would be no increased risk of flooding to areas outside the 

property. All developed areas within the Special Flood Hazard Area would be filled prior to construction to bring 

the ground surface approximately 2 feet above Base Flood Elevation.

The military housing component would have the same requirements for post-construction stormwater controls as 

described for the MILCON Alternative. Any private development done as part of the EUL would be required to 

meet post-construction stormwater control requirements of Doral and Miami-Dade County to minimize an 
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increase in the volume of offsite stormwater runoff from an increase in impervious area, approximately 82 acres.

Similar to the MILCON Alternative, flood hazards in this area would be from ponding and storm surge events. 

Flood risks in this area would not be associated with conveyance or volume of streamflow. In addition, postconstruction stormwater controls would maintain pre-development run-off rates and volumes. Therefore, no 

increased risk of flooding for other properties would be expected. The EUL Alternative would have a greater 

adverse impact on flood hazards compared to the MILCON Alternative, due to the larger area of impervious 

surface. However, because post-construction stormwater controls would maintain pre-development run-off rates 

and volumes, the long-term adverse direct impacts are expected to be minor. The increase in impervious surface 

under this alternative would have a less than significant indirect adverse effect on flood hazard area because the 

stormwater controls would minimize runoff increase. Further, while the project area is greater than the MILCON 

Alternative, it would be less than 0.1 percent of the surrounding area, which would result in less than 0.01 inch in 

rise of floodwater in the region.

3.7.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.7.1 

would continue. There would be no change in impacts to flood hazards from current conditions.

3.8 Air Quality

3.8.1 Regulatory Setting

3.8.1.1 Federal 

Under the authority of the CAA, U.S. Environmental Protection Agency (EPA) has established nationwide air 

quality standards to protect public health and welfare. These federal standards, known as National Ambient Air 

Quality Standards (NAAQS) and shown in Table 3-1, represent the maximum allowable atmospheric 

concentrations for six criteria pollutants: ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur 

dioxide (SO2), lead, and particulate matter (which includes respirable particulate matter less than or equal to 

10 micrometers in diameter [PM10] and respirable particulate matter less than or equal to 2.5 micrometers in 

diameter [PM2.5]).

Table 3-1. National Ambient Air Quality Standards

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Criteria Pollutant Federal Standard (Averaging Period) a

CO 35 ppm (1 hour)

9 ppm (8 hours)

NO2 0.100 ppm (1 hour)

0.053 ppm

(annual arithmetic mean)

O3 0.070 ppm (8 hours)

PM2.5

12 μg/m3 

(annual arithmetic mean)

35 μg /m3 (24 hours) b

PM10 150 μg/m3 (24 hours)

SO2

0.5 ppm (3 hours, secondary standard)

0.075 ppm (1 hour) b
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Table 3-1. National Ambient Air Quality Standards

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Criteria Pollutant Federal Standard (Averaging Period) a

Lead 0.15 μg/m3

(rolling 3-month average)

Source: EPA, 2019a

a National standards other than O3, particulate matter (PM), and those based on annual averages or annual arithmetic 

means are not to be exceeded more than once a year. The O3 standard is attained when the fourth highest eight-hour 

concentration in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard 

is attained when the expected number of days per calendar year with a 24-hour average concentration above 

150 μg/m3 is equal to or less than 1. For PM2.5, the 24-hour standard is attained when 98 percent of the daily 

concentrations, averaged over three years, is equal to or less than the standard.

b To attain this standard, the three-year average of the 99th percentile of the daily maximum one-hour average at each 

monitor within an area must not exceed 75 parts per billion.

μg/m3 =micrograms per cubic meter

ppm = parts per million, by volume

NA = not applicable

Under the CAA, the country is classified into attainment, nonattainment, and maintenance areas. Any area not 

meeting the NAAQS is designated as nonattainment for the specific pollutant or pollutants, whereas areas that 

meet the NAAQS are designated as attainment areas. Maintenance areas are those areas that were previously 

designated as nonattainment and subsequently redesignated as attainment, subject to development of a 

maintenance plan.

Under the EPA New Source Review (NSR) program, stationary sources of air pollution are required to have permits 

before construction of the source begins. NSR Prevention of Significant Deterioration permit approval would be 

required if the proposed project was either: (1) a new source, with the potential to emit 250 tons per year or 

more of an attainment pollutant; or (2) an existing major source of emissions, making a major modification in an 

attainment area, and resulting in a net emission increase above specified levels. Nonattainment NSR approval 

would be required if the proposed project were a new stationary source or major source of emissions that made a 

major modification in a nonattainment area with potential to emit nonattainment pollutants in excess of the NSR 

thresholds.

The CAA General Conformity Rule (40 CFR, Parts 6, 51, and 93) requires federal agencies to make written 

conformity determinations for federal actions in or affecting nonattainment or maintenance areas. If the 

emissions of a criteria pollutant (or its precursors) do not exceed the de minimis level, then the federal action has 

minimal air quality impact and the action is determined to conform for the pollutant under study; therefore, no 

further analysis is necessary. Greenhouse gases (GHGs) are compounds that may contribute to accelerated 

climate change by altering the thermodynamic properties of the earth’s atmosphere. GHGs consist of carbon 

dioxide (CO2), methane, nitrous oxide, and fluorinated gases (EPA, 2016). Under the EPA Mandatory Reporting 

Rule, facilities that emit 25,000 metric tons or more per year of carbon dioxide equivalent (CO2e) emissions must 

submit annual reports to the EPA.

3.8.1.2 State 

The Florida Department of Environmental Protection (FDEP) oversees the permitting of air pollution sources in 

Florida. Under Florida Administrative Code (FAC), Chapter 62-296.320, “General Pollutant Emission Limiting 

Standards,” Section (4)(c), no person shall allow the emissions of unconfined particulate matter (PM) from any 

activity, including but not limited to construction, without taking measures to prevent PM emissions. Preventive 

measures may include application of water to control emissions from demolition of buildings, grading, 

construction and land clearing and landscaping or planting of vegetation.
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3.8.2 Affected Environment

Miami-Dade County, where the proposed project area is located, is in attainment for all criteria air pollutants 

(EPA, 2019b). The air quality in Miami-Dade County typically falls in the “Good” range on EPA’s Air Quality Index 

throughout the year, which means that air quality is considered satisfactory and air pollution poses little or no risk

(Miami-Dade County, 2016; AirNow, 2019). In 2018, PM2.5 and O3 were the primary air pollutants in Miami-Dade 

County (EPA, 2018).

3.8.3 Environmental Consequences

3.8.3.1 MILCON Alternative 

Air quality impacts associated with the MILCON Alternative were evaluated based on whether emissions would be 

localized, and whether a reasonable potential exists for a violation of an ambient air quality standard or 

regulatory threshold. A conformity analysis is not mandatory for attainment areas; however, an estimate is 

provided to show that emissions from the MILCON Alternative would be less than the de minimis levels 

established in the conformity regulation. Implementation of the MILCON Alternative at USAG-Miami would result 

in minor short-term adverse direct impacts on overall air quality from construction activities. The operation of 

various construction equipment during construction activities would create exhaust emissions, and generate dust 

and other particles in the air during the execution of the MILCON Alternative. Mobile source emissions also would 

be generated from vehicular traffic. Implementation of the MILCON Alternative at USAG-Miami would result in 

minor long-term adverse direct impacts on overall air quality from operational activities. Operational emissions 

would result from the use of comfort heating systems installed in new facilities, recurring landscaping services, 

and commuting by residents.

Measures that would be implemented to reduce or eliminate fugitive dust emissions include the following:

• Sprinkling/Irrigation. Sprinkling the ground surface with water until it is moist is an effective dust control 

method for haul roads and other traffic routes (Alabama Soil and Water Conservation Committee, 2014). This 

practice can be used at virtually any site. When suppression methods involving water are used, care would be 

exercised to minimize over-watering that could cause the transport of mud onto adjoining roadways, which 

ultimately could increase the dust problem. Mechanical removal of mud from tires would be implemented if 

necessary.

• Vegetative Cover. In areas not expected to accommodate vehicle traffic, vegetative stabilization of disturbed 

soil is often desirable. Vegetation provides coverage to surface soils and decreases wind velocity at the 

ground surface, thus reducing the potential for dust to become airborne. 

• Mulch. Mulching can be a quick and effective means of dust control for recently disturbed areas. 

Construction Emissions. Construction emissions were estimated using the U.S. Air Force’s Air Conformity 

Applicability Model (version 5.0.7). Construction activities would include construction, excavation, and paving 

associated with new facilities and amenities. Construction was assumed to begin in October 2023 and end in

October 2026.

No new air emission sources would result from the MILCON Alternative once it is constructed. Table 3-2

summarizes the projected total air emissions from construction of the MILCON Alternative. A copy of the 

calculations used to develop these estimates is in Appendix D.
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Table 3-2. MILCON Alternative Emissions 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida 

Emission Source

Emissions for 2023 (tons per year)

VOC CO NOX SO2 PM10 PM2.5 Pb

2023 Construction Emissions

(tons per year) 0.065 0.519 0.349 0.001 0.012 0.012 0

de minimis levels (tons per year) 100 100 100 100 100 100 100

Threshold Exceeded for Any 

Activity? -- -- -- -- -- -- --

Emission Source

Emissions for 2024 (tons per year)

VOC CO NOX SO2 PM10 PM2.5 Pb

2024 Construction Emissions

(tons per year) 1.54 3.74 2.60 0.008 0.098 0.098 0

de minimis levels (tons per year) 100 100 100 100 100 100 100

Threshold Exceeded for Any 

Activity? -- -- -- -- -- -- --

Emission Source

Emissions for 2025 (tons per year)

VOC CO NOX SO2 PM10 PM2.5 Pb

2025 Construction Emissions

(tons per year) 3.97 9.70 15.2 0.051 93.5 0.584 0

de minimis levels (tons per year) 100 100 100 100 100 100 100

Threshold Exceeded for Any 

Activity? -- -- -- -- -- -- --

Emission Source

Emissions for 2026 (tons per year)

VOC CO NOX SO2 PM10 PM2.5 Pb

2026 Construction Emissions

(tons per year) 1.61 7.25 13.6 0.045 49.9 0.537 0

de minimis levels (tons per year) 100 100 100 100 100 100 100

Threshold Exceeded for 

Any Activity? -- -- -- -- -- -- --

Source: Appendix D, Air Quality Emission Estimates and Record of Non-Applicability

NOx = nitrogen oxides

VOC = volatile organic compound

Based on the estimated emissions listed in Table 3-2, the emissions from construction activities associated with 

the MILCON Alternative would be below regulatory thresholds. Therefore, the MILCON Alternative would not be 

subject to Prevention of Significant Deterioration permit or NSR requirements. Analysis indicates that emissions 

would be below the de minimis thresholds. Although not required, a Record of Non-applicability is provided in 

Appendix D to document that the MILCON Alternative is exempt from general conformity requirements. Appendix 

D also contains detailed emission calculations. 

Climate Change and Greenhouse Gases. The MILCON Alternative would generate GHG emissions from 

construction-related activities. Construction of the military housing project would result in a short-term, 

insignificant increase in GHG emissions. Estimated peak GHG emissions would be 5,535 tons CO2e for construction 

in 2025. The EPA Mandatory Reporting Rule reporting value of 25,000 metric tons per year of CO2e emissions is 

used as the significance threshold for this analysis. Therefore, short-term, minor, adverse indirect impacts to 

climate change as a result of GHG emissions at USAG-Miami would be expected from implementation of the 

MILCON Alternative. 
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Under the MILCON Alternative, military personnel would be housed within walking distance to SOUTHCOM 

headquarters. This would eliminate daily commutes of up to 40 miles round trip for approximately 150 personnel. 

Long-term minor beneficial direct impacts to air quality and GHG emissions would result from military personnel 

walking rather than driving to their workplace.

3.8.3.2 EUL Alternative 

Under the EUL Alternative, impacts to air quality would be comparable to those discussed for the MILCON 

Alternative (Section 3.8.3.1), but would be greater because of the additional construction and operational 

emissions from the mixed-use development. The EUL would have a greater adverse impact on air quality 

compared to the MILCON Alternative, not only from a larger development but also the longer construction 

duration. While the impacts would be greater, they would be in an attainment area and would be under air 

quality thresholds and would result in minor short-term adverse direct impacts from construction activities. 

Operational emissions would result from the use of comfort heating systems installed in new facilities, recurring 

landscaping services, and commuting by residents and retail patrons. Similar to the MILCON Alternative, 

implementation of the EUL Alternative would result in minor long-term adverse direct impacts on overall air 

quality from operational activities.

Construction Emissions. Construction emissions were estimated using the U.S. Air Force’s Air Conformity 

Applicability Model (version 5.0.7). Construction activities would include construction excavation and paving 

associated with new facilities. Construction was assumed to begin in January 2024 and end in December 2024.

Table 3-3 summarizes the projected total air emissions from construction of the EUL Alternative. A copy of the 

calculations used to develop these estimates is in Appendix D.

Table 3-3. EUL Alternative Emissions 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida 

Emission Source

Emissions for 2024 (tons per year)

VOC CO NOX SO2 PM10 PM2.5

2024 Construction Emissions for

Housing Development 1.54 3.74 2.60 0.008 0.098 0.098

2024 Construction Emissions for 

Mixed-Use Development 3.61 3.52 2.70 0.008 0.114 0.113

2024 Total Construction Emissions 5.15 7.26 5.30 0.016 0.212 0.211

de minimis levels (tons per year) 100 100 100 100 100 100

Threshold Exceeded for Any Activity? -- -- -- -- -- --

Based on the estimated emissions listed in Table 3-3, the emissions from construction activities associated with 

the EUL Alternative would be below regulatory thresholds. Therefore, the EUL Alternative would not be subject to 

Prevention of Significant Deterioration permit or NSR requirements. Analysis indicates that emissions would be 

below the de minimis thresholds. Although not required, a Record of Non-applicability is provided in Appendix D

to document that the EUL Alternative is exempt from general conformity requirements. Appendix D also contains 

detailed emission calculations. 

Climate Change and Greenhouse Gases. The EUL Alternative would generate GHG emissions from constructionrelated activities. Construction of the EUL Alternative would result in a short-term, insignificant increase in GHG 

emissions. In addition to GHG emissions associated with construction of the housing development described for 

the MILCON Alternative, there would be an additional estimated 1,311 metric tons CO2e of GHG emissions for

construction of the mixed-use development in 2024, for a total of 6,846 metric tons of CO2e emissions well below 

the significance threshold of 25,000 metric tons per year of CO2e emissions. Therefore, short-term, minor, adverse 
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

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indirect impacts to climate change as a result of GHG emissions at USAG-Miami would be expected from 

implementation of the EUL Alternative. 

Under the EUL Alternative, military personnel would be housed within walking distance to SOUTHCOM 

headquarters. This would eliminate daily commutes of up to 40 miles round trip for approximately 150 personnel. 

Long-term minor beneficial direct impacts to air quality and greenhouse gas emissions would result from military 

personnel walking rather than driving to their workplace. There could be long-term minor adverse direct impacts 

on air quality from an increase in vehicles on local roads from the use of the new mixed-use development. 

However, depending on actual use, there could be a long-term minor beneficial direct impact on air quality, as 

services would be provided closer to where people live, which would reduce overall miles driven and associated 

vehicle emissions.

3.8.3.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.8.2 

would continue. There would be no impacts to air quality from the Proposed Action.

3.9 Noise

Noise is defined as unwanted or annoying sound that interferes with or disrupts normal human activities such as 

sleep, conversation, or student learning. A number of noise measurements are normally considered when 

determining noise impacts and include the following:

• Decibel (dB): A measurement of the sound pressure level.

• dBA (A-weighted sound pressure level): Sound pressure level adjusted by an A-weighting filter. The 

A-weighting filter places greater emphasis on those frequencies within the sensitive range of the human ear 

by de-emphasizing the very low and very high frequency components. Typically, human hearing is best 

approximated by using a dBA scale (EPA, 1974). 

• dBC (C-weighted sound pressure level): Sound pressure level adjusted by a C-weighting filter, which 

emphasizes the very low frequency components of sound. 

The decibel scale is logarithmic rather than arithmetic. When sound pressure doubles, the sound pressure level, 

as expressed by dBA, increases by 3. Psychologically, most humans do not perceive a doubling of sound until there 

is an increase of 10 dBA (EPA, 1974). Sound pressure decreases with distance from the source. Typically, the 

amount of noise from a continuous source is halved (reduced by 3 dBA) as the distance from the source doubles 

(EPA, 1974). However, other factors including ground type, atmospheric conditions, and shielding by vegetation 

and structures further affect the amount of decrease in sound over distance (USDOT, 2011).

FAA and U.S. Department of Housing and Urban Development criteria specify that noise levels in noise-sensitive 

land use areas normally are considered unacceptable where they exceed a day-night average sound level (DNL) of 

65 dBA.

3.9.1 Affected Environment

There are no permanent sources of noise on the 160-acre parcel. Noise from the surrounding area comes from 

local traffic and from the Miami International Airport, approximately 3 miles to the east. Noise contours were 

developed for the Miami International Airport using FAA’s Aviation Environmental Design Tool for the calendar 

year 2017 (Environmental Science Associates, 2018). Most of the parcel is outside of the 65 DNL contour and 

therefore has no land use restrictions. A small portion of the eastern part of the parcel is within the 65 to 70 DNL 

contour. In accordance with FAA Order 1050.1F – Policies and Procedures for Considering Environmental Impacts

(FAA, 2015), residential land use and related structures within the 65 to 70 DNL noise contour are not compatible 

and should be prohibited unless noise reduction measures are incorporated into building codes.

The City of Doral Noise Ordinance specifies that construction equipment must be operated in accordance with 

manufacturer’s specifications, be in good working condition, and use noise baffling methods (City of Doral, 2006). 
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

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The noise ordinance also states that construction should only occur between the hours of 8 a.m. and 6 p.m. on 

weekdays and between the hours of 10 a.m. and 4 p.m. on Saturdays in areas zoned as residential or in areas 

zoned as business, industrial, or non-residential where the property on which the construction occurs directly 

abuts or is adjacent to a residentially zoned property (City of Doral, 2006). Residences are west of the parcel 

across NW 97th Avenue and a city park is east of the parcel across NW 97th Avenue.

3.9.2 Environmental Consequences

3.9.2.1 MILCON Alternative 

Under the MILCON Alternative, there would be a short-term moderate direct adverse impact from noise 

associated with construction. Construction noise would be greatest early in the construction project, during 

clearing, grading, foundation work, and paving. 

Construction activity in the northwestern part of the parcel would be within 200 feet of houses west of NW 97th

Avenue. These residences would be subjected to temporary noise levels above 80 dBA during use of heavy 

equipment, which would make outdoor activities unpleasant; however, this would not cause the DNL to exceed 

65 dBA. Residential structures typically provide an attenuation of 15 to 25 dBA, relative to outdoor noise levels 

(EPA, 1974), and indoor activities also would be adversely affected by heavy equipment operation. While 

annoying and disruptive, these noise levels would not pose a risk to the hearing ability of residents. Persons using 

Doral Central Park during times of construction also may experience annoyance and likely would avoid areas in 

the park closest to the active construction. To minimize potential adverse noise impacts, the construction 

activities would be limited to the hours listed in the City of Doral Noise Ordinance. Also, the contractor would be 

required to maintain construction equipment in accordance with manufacturer’s specifications to keep 

unnecessary noise impacts to a minimum. Construction noise impacts would be adverse, direct, and temporary, 

and would range from negligible to moderate in intensity depending on proximity of houses to the construction 

area. Temporary, construction-related adverse noise impacts would end once construction is complete. 

In the event that buildings are constructed within the 65 to 70 DNL noise contour for the Miami International 

Airport, which overlaps a small portion of the eastern part of the parcel, measures to achieve outdoor to indoor 

noise level reduction of at least 25 dBA would be incorporated into the design in accordance with FAA Order 

1050.1F. Negligible long-term adverse indoor direct impacts from noise would be expected at any of the proposed 

residences.

After construction, noise emanating from the parcel would be typical of a residential neighborhood. Therefore, 

there would be no long-term impacts to noise-sensitive receptors from MILCON Alternative.

3.9.2.2 EUL Alternative 

Under the EUL Alternative, the impacts to noise described for the MILCON Alternative (Section 3.9.2.1) would 

occur, but would be greater because it would extend to a larger area due to construction of the mixed-use 

development. This would increase the number of residences exposed to construction noise. Construction of the 

mixed-use development would follow the same guidelines as those described under the MILCON Alternative. 

Construction noise impacts would be adverse, direct, and temporary, and would range from minor to moderate in 

intensity depending on proximity of houses to the construction area. Temporary, construction-related, adverse 

noise impacts would end once construction is complete. 

In the event that buildings are constructed within the 65 to 70 DNL noise contour for the Miami International 

Airport, which overlaps a small portion of the eastern part of the parcel, measures to achieve outdoor to indoor 

noise level reduction of at least 25 dBA would be incorporated into the design in accordance with FAA Order 

1050.1F. Negligible long-term adverse indoor direct impacts from noise would be expected at any of the proposed 

residences. 

After construction, noise emanating from the northern portion of the parcel would be typical of a residential 

neighborhood and typical of a shopping or retail area from the south. Therefore, there would be negligible longterm adverse direct impacts to noise-sensitive receptors from EUL Alternative.
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

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3.9.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.9.1 

would continue. There would be no impacts to noise from the Proposed Action.

3.10 Biological Resources

Biological resources include plants (flora) and animals (fauna) and the habitats in which they occur. Major 

vegetation communities are described in terms of the representative species present, with special attention 

placed on special-status species afforded some level of federal, state, or local protection. General wildlife species 

expected to occur are described, with emphasis placed on special-status species. 

3.10.1 Regulatory Considerations

3.10.1.1 Endangered Species Act of 1973 

ESA 16 U.S.C. Sections 1531 et seq. was established to protect and allow for recovery of species threatened or 

endangered from becoming extinct. Under the ESA, species may be listed as endangered or threatened. 

Endangered species include those in danger of extinction throughout all or a part of its range. Threatened species 

are those likely to become endangered within the foreseeable future. The ESA also protects habitat considered 

critical to the existence and recovery of listed species. Section 7(a)(2) of the ESA requires that each federal 

agency, in consultation with the Secretary [U.S. Fish and Wildlife Service (USFWS) and/or National Marine 

Fisheries Service (now designated as NOAA Fisheries)], ensure that any action they authorize, fund, or carry out is 

not likely to jeopardize the continued existence of a listed species or result in the destruction or adverse 

modification of designated critical habitat.

3.10.1.2 Migratory Bird Treaty Act 

The purpose of MBTA 16 U.S.C. Section 703 et seq. is to allow for protection of bird species that migrate between 

the United States and other countries. The MBTA states that it is unlawful to pursue, hunt, take, capture, kill,

possess, sell, purchase, barter, import, export, or transport any migratory bird, or any part, nest, or egg or any 

such bird, unless authorized under a permit issued by the Secretary of the Interior. Take is defined in regulations 

as: “pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to pursue, hunt, shoot, wound, kill, trap, 

capture, or collect.” The list of bird species protected by the MBTA is included in 50 CFR Section 10.13.

3.10.2 Affected Environment

3.10.2.1 Flora 

Vegetation on the FAA parcel consists of mostly grasslands with some rowed trees. The site was historically and is 

currently being used for agricultural and cow pasture purposes. Native plant species observed in the project area 

during a site visit on July 11, 2019 included annual ragweed (Ambrosia artemisiifolia), beggarticks (Bidens alba),

blue mistflower (Conoclinium coelestinum), frogfruit (Phyla nodiflora), common wireweed (Sida acuta), 

coffeeweed (Senna obtusifolia), and Carolina horsenettle (Solanum carolinense). Non-native plants included

tropical milkweed (Asclepias curassavica), crowfoot grass (Dactyloctenium aegyptium), soda apple (Solanum 

capsicoides), and tropical soda apple (Solanum viarum). Pasture grasses dominate the FAA parcel and consist of

multiple Bahia grasses (Paspalum spp.).

Special-status Flora

Special-status flora species of interest include the following: 

• Species listed as threatened, endangered, proposed for listing, or candidate for listing under the ESA 

• Species listed as state endangered, threatened, or commercially exploited
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• Species designated by USFWS as Species of Concern, representing those species formerly designated as 

candidates for listing as endangered or threatened, but for which information is insufficient to make a 

determination

Nineteen plant species that are federal or state-listed were identified as having potential to occur in the project 

area (Table 3-4). Table 3-4 also identifies whether habitat for these species occurs within the project area.

Table 3-4. Protected Plant Species with Potential to Occur in the Proposed Project Area 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida 

Scientific Name Common Name Status Habitat Present for Species

Argythamnia blodgettii Blodgett’s silverbush FT, SE None

Amorpha crenulata Crenulate lead-plant FE, SE None

Brickellia mosieri Florida brickell-bush FE, SE None

Chamaesyce deltoidea ssp. deltoidea Deltoid spurge FE, SE None

Chamaesyce garberi Garber’s spurge FT, SE None

Chamaesyce deltoidea pinetorum Pineland sandmat FT, SE None

Chromolaena frustrata Cape Sable thoroughwort FE, SE None

Consolea corallicola Florida semaphore cactus FE, SE None

Cucurbita okeechobeensis ssp. 

okeechobeensis Okeechobee gourd FE, SE None

Dalea carthagenensis floridana Florida prairie-clover FE, SE None

Digitaria pauciflora Florida pineland crabgrass FT, SE None

Galactia smallii Small’s milkpea FE, SE None

Jacquemontia reclinata Beach jacquemontia FE, SE None

Linum arenicola Sand flax FE, SE None

Linum carteri Carter’s small-flowered flax FE, SE None

Polygala smallii Tiny polygala FE, SE None

Sideroxylon reclinatum ssp. austrofloridense Everglades bully FT None

Trichomanes punctatum ssp. floridanum Florida bristle fern FE, SE None

Warea carteri Carter’s mustard FE, SE None

Notes:

FT = federally threatened, FE = federally endangered, SE = state endangered, ST = state threatened

Sources: USFWS, 2019a; FDACS, 2018

Descriptions of special-status species are included in Appendix E.

Field Survey Results

No federally protected or state-protected plant species were identified within or adjacent to the proposed project 

area. The regular mowing near the FAA antenna, the continual cattle grazing, and the abundance of exotic 

invasive species result in the project area being generally unsuitable to support listed pant species.

3.10.2.2 General Wildlife 

Wildlife

The proposed project area is currently used for grazing cows and is surrounded by residential, commercial, and 

industrial development, with the exception of Doral Central Park which is east of NW 92nd Avenue by the 

northeastern portion of the FAA parcel. The FAA parcel and Doral Central Park are surrounded by urban 

development and lack connectivity with any natural habitat or undisturbed lands.
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3‐19 

Common wildlife in urbanized areas of Miami‐Dade County include common raccoon (Procyon lotor), bobcat (Lynx 

rufus), feral cat (Felis catus), northern mockingbird (Mimus polyglottos), common grackle (Quiscalus quiscula), 

blue jay (Cyanocitta cristata), house sparrow (Passer domesticus), northern cardinal (Cardinalis cardinalis), rock 

dove (Columba livia), mourning dove (Zenaida macroura), tree frogs (Hyla spp.), and American alligator (Alligator 

mississippiensis). Animals observed within the project area during a site visit conducted on July 11, 2019 included 

cows (Bos taurus), great egret (Ardea alba), and red‐winged blackbird (Agelaius phoeniceus).  

3.10.2.3 Special‐status Fauna 

Special‐status fauna species of interest include the following:  

 Species listed as threatened, endangered, proposed for listing, or candidate for listing under the ESA 

 Species listed as state endangered, threatened, or Species of Special Concern  

Twenty‐six wildlife species that are federal or state‐listed were identified as having potential to occur in the 

project area (Table 3‐5).  

Table 3‐5. Protected Wildlife Species with Potential to Occur in the Proposed Project Area  

Construction of a Military Housing Development for USAG‐Miami, Doral, Florida 

  Common Name  Scientific Name  Status  Potential for 

Occurrence 

Birds  Bachman’s warbler  Vermivora bachmanii  FE  Highly Unlikely 

Cape Sable seaside sparrow  Ammodramus maritimus mirabilis  FE  Highly Unlikely 

Everglade snail kite  Rostrhamus sociabilis plumbeus  FE  Highly Unlikely 

Florida burrowing owl  Athene cunicularia floridana  ST  Moderate 

Florida grasshopper sparrow  Ammodramus savannarum  FE  Highly Unlikely 

Florida scrub‐jay  Aphelocoma coerulescens  FT  Highly Unlikely 

Ivory‐billed woodpecker  Campephilus principalis  FE  Highly Unlikely 

Kirtland’s warbler   Setophaga kirtlandii  FE  Unlikely 

Least tern  Sternula antillarum  ST  Unlikely 

Piping plover  Charadrius melodus  FT  Highly Unlikely 

Red knot  Calidris canutus rufa  FT  Highly Unlikely 

Red‐cockaded woodpecker  Dryobates (formerly Picoides)

borealis 

FE  Highly Unlikely 

Southeastern American kestrel  Falco sparverius Paulus  ST  Moderate 

White‐crowned pigeon  Patagioenas leucocephala  ST  Highly Unlikely 

Wood stork  Mycteria Americana  FT  Unlikely 

Invertebrates  Bartram’s scrub‐hairstreak  Strymon acis bartrami  FE  Highly Unlikely 

Florida leafwing butterfly  Anaea troglodyta floridalis  FE  Highly Unlikely 

Miami blue butterfly  Cyclargus thomasi bethunebakeri  FE  Highly Unlikely 

Schaus swallowtail butterfly  Papilioaristodemus ponceanus  FE  Highly Unlikely 

Stock Island tree snail  Orthalicus reses  FT  Unlikely 

   
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Table 3‐5. Protected Wildlife Species with Potential to Occur in the Proposed Project Area  

Construction of a Military Housing Development for USAG‐Miami, Doral, Florida 

  Common Name  Scientific Name  Status  Potential for 

Occurrence 

Mammals  Florida bonneted bat  Eumops floridanus  FE  Unlikely 

Florida panther  Puma concolor coryi  FE  Highly Unlikely 

Mountain lion  Puma concolor  FT(S/A)  Highly Unlikely 

Reptiles  American alligator  Alligator mississippiensis  FT(S/A)  Unlikely 

American crocodile  Crocodylus acutus  FT  Unlikely 

Eastern indigo snake  Drymarchon corais couperi  FT  Unlikely 

FE = Federally endangered  

FT = Federally threatened  

FT(S/A) = Federally threatened species due to similarity of appearance  

Source: USFWS, 2019a; FFWCC, 2018 

Descriptions of special‐status species are included in Appendix E. No federally protected animal species are known 

to occur within the proposed project area and occurrence is unlikely due to the extent of encroachment by 

invasive exotic plant species and the high level of disturbance and surrounding development. According to the 

USFWS Threatened and Endangered Species Active Critical Habitat Report, no critical habitats are located within 

the subject property. Critical habitat for West Indian manatee (Trichechus manatus) is located 1.5 miles east of 

the subject property (USFWS, 2019b). No suitable habitat for West Indian manatee occurs within the proposed 

project area. 

3.10.3 Environmental Consequences 

3.10.3.1 MILCON Alternative 

Vegetation 

Existing vegetation within the proposed project area is dominated by exotic species. The MILCON Alternative 

would result in grading up to 75 acres. However, removal of the predominately non‐native vegetation, including 

multiple invasive species, would result in long‐term less than significant adverse direct impacts. Adverse impacts 

on vegetation would be expected from temporary disturbances during construction activities (e.g., trampling and 

removal) and from the permanent removal of the predominately non‐native vegetation from the construction of 

new facilities. There would also be a loss of vegetation within the area around the FAA antenna if stormwater 

retention infrastructure, roads, or parking were placed in this 52.4‐acre central area. 

Wildlife 

The MILCON Alternative would result in minor short‐term direct adverse impacts on wildlife due to disturbances 

from noise, construction activities, and heavy equipment use.  

The MILCON Alternative would result in long‐term minor direct adverse impacts to wildlife from the conversion of 

undeveloped areas to developed impervious areas. Impacts would be minor because of the low‐quality of wildlife 

habitat within the proposed project area and because wildlife in the vicinity of the proposed project area are 

species that are tolerant of noise and human activity common in urban environments.  

During land clearing and grading, limited incidental injury or mortality of wildlife could occur. However, it is 

expected that wildlife would avoid the active construction sites and adjacent areas during construction. If 

common wildlife species are observed in the construction areas, efforts would be made to allow them to leave 

the area. No habitat would be lost outside the boundaries of the FAA parcel. Incidental losses of animals during 

construction would not seriously affect regional animal population levels. 
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

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Special-status Species

There is no suitable habitat for special-status plant species within the project area; therefore, no impacts to 

special-status plants are expected under the MILCON Alternative. 

The state-threatened Florida burrowing owl is known to occur within the City of Doral. However, the habitat 

quality onsite is poor and no burrows were observed during the site visit. This species is unlikely to nest within the 

proposed project area. If the Florida burrowing owl is observed during visual scans of the work areas, work would 

be suspended or would not start, and the owl would be allowed to voluntarily fly off without being prompted to 

fly. Any adverse impacts would be direct, short-term, and negligible and limited to displacement of foraging 

animals.

The state-threatened Southeastern American kestrel is known to occur in Miami-Dade County. This species could 

forage on the FAA parcel, but there is no nesting habitat for the species on the parcel. Foraging birds would leave 

the area when construction activity begins and there would be no mortality of this species. If the Southeastern 

American kestrel is observed during visual scans of the work areas, work would be suspended or would not start,

and the kestrel would be allowed to voluntarily fly off without being prompted to fly. Any adverse impacts would 

be direct, short-term, and negligible and limited to displacement of foraging animals.

The American alligator and crocodile may occur in the canals near the proposed construction site, but there is no 

onsite use because the canals are fenced off. Construction activities would not result in disturbances to the 

species and no mortality would be expected.

No federally protected animal species are known to occur within the proposed project area and occurrence is 

unlikely due to the extent of encroachment by invasive exotic plant species and the high level of disturbance and 

surrounding development. USAG-Miami has determined there would be no effect to federally threatened, 

endangered, or candidate species or their habitats and no consultation with USFWS is necessary.

If any protected species are observed within the construction areas, construction would stop until the protected 

species voluntarily leaves the construction area. 

Because project impacts would be confined to the project property and no habitat fragmentation or disruption to 

wildlife corridors would occur due to the subject property and adjacent Doral Park being surrounded by urban 

development and already lack connectivity with any natural habitat or undisturbed lands. Although project 

impacts would be confined to the project property, adverse indirect impacts to biological resources could include 

displacement or avoidance due to noise and vibration from the operation of heavy equipment. Mortality of 

ground-dwelling animals with limited dispersal capability likely would result, but this mortality would not be 

expected to affect regional populations of common wildlife. Therefore, negligible long-term adverse indirect 

impacts to biological resources would be expected under the Proposed Action.

3.10.3.2 EUL Alternative 

Under the EUL Alternative, the types of impacts to biological resources as described for the MILCON Alternative 

(Section 3.10.3.1) would occur over an additional 32.5 acres. The larger area of construction associated with the 

mixed-use development could increase the duration and area of construction-related impacts; however, longterm adverse direct and indirect impacts would still be less than significant due to the low quality of the habitat 

on the site and relatively low number of native species inhabiting the area.

3.10.3.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.10.2 

would continue. There would be no impacts to biological resources from the Proposed Action.
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

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3.11 Cultural Resources

3.11.1 Affected Environment

According to a search conducted with the Florida Master Site File at the Florida Division of Historic Resources on 

December 07, 2020 and the Miami-Dade County Office of Historic Preservation, there are no identified historic 

properties within the project area. A substantial portion of the FAA parcel was previously disturbed from 

construction of the antenna and support buildings and for other infrastructure that has since been removed from 

the site. There have also been ground disturbance from cattle grazing in the area. Therefore, no additional 

archaeological surveys are considered necessary within the proposed project area.

3.11.2 Environmental Consequences

3.11.2.1 MILCON Alternative 

Under the MILCON Alternative, there would be no direct impacts to known cultural resources since none have 

been identified within the project area. In the event of an inadvertent discovery of archaeological resources or 

human remains during site preparation, work would be halted and USAG-Miami would notify the Florida Division 

of Historical Resources. Work would resume when deemed appropriate. Implementation of procedures for 

inadvertent discovery of resources would mitigate potential impacts to less than significant.

There would be no indirect impacts to identified cultural resources under the MILCON Alternative, because no 

resources are known to be present in or near the project area.

3.11.2.2 EUL Alternative 

Under the EUL Alternative, impacts to cultural resources would be identical to the MILCON Alternative (Section 

3.11.2.1).

3.11.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.11.1 

would continue. There would be no impacts to cultural resources under the No Action Alternative.

3.12 Socioeconomic Resources

3.12.1 Affected Environment

3.12.1.1 Economic Development 

The largest employment sectors for workers in Miami-Dade County include health care and social assistance, 

retail trade, and accommodation and food service (Miami-Dade County, 2019a). In 2017, there were 1,775,721 

jobs in Miami-Dade County and the average annual wages and salaries were $54,946 (Bureau of Economic 

Analysis, 2019). The City of Doral has a labor force of 26,314 people and a 4.5 percent unemployment rate. Doral 

is one of the fastest growing cities in Florida, with more than 2 million square feet in approved commercial 

developments, over 9,000 residential units approved, and various mixed-use developments approved (City of 

Doral, 2019b). More than 150,000 people travel to jobs at businesses in Doral on a daily basis (City of Doral, 

2019c).

On the FAA parcel, one person gains economic benefits from grazing cattle on the property.

3.12.1.2 Public Services 

The Miami-Dade County Police Department (Station 3) is located adjacent to the southeastern border of the FAA 

parcel and the Miami-Dade Fire Department is located immediately north of SOUTHCOM, approximately 0.4 mile 

north of the FAA parcel.
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

3-23

A new 100-bed hospital, José Milton Memorial Hospital, will open at the Jackson West Medical Center in Doral in 

2020. The hospital is located approximately 1.3 miles east of the proposed project area and will provide two 

emergency rooms (one for adults, one for children), diagnostic services, operating rooms, and outpatient facilities 

(San Juan, 2019).

Doral, Florida is within the Miami-Dade school district. There are a multitude of highly-rated public, private, and 

charter schools in Doral. In total, there are 23 preschools, 9 elementary schools, 10 middle schools, and 5 high 

schools. This includes 6 public district schools, 9 public charter schools, and 20 private schools (GreatSchools, 

2019). 

3.12.1.3 Housing 

The City of Doral has a population of over 64,000 residents and has grown 77 percent in the last eight years (City 

of Doral, 2019c). There are 16,626 households in Doral with an average of 3.38 persons per household. The 

median gross rent between 2013 and 2017 was $1,834 and the median value of owner-occupied housing units 

was $349,800 (U.S. Census Bureau, 2018a).

No military housing exists on the USAG-Miami cantonment.

3.12.2 Environmental Consequences

3.12.2.1 MILCON Alternative 

The MILCON Alternative would have temporary minor to moderate beneficial impacts on economic development. 

There would be temporary construction employment and associated wages. In addition, local suppliers could 

experience a short-term increase in demand for construction-related materials. The MILCON Alternative would 

have minor long-term beneficial impacts on employment in the surrounding area. Housing and maintenance hires 

would be from the local community and the community center would likely be staffed by one part-time person. 

There would be negligible long-term adverse direct economic impacts from the reduction in cattle production on 

the FAA parcel. The adverse economic impact of this small cattle operation is negligible within the context of the 

economy of the greater Miami area.

Approximately 600 people would relocate from within the region into the proposed military housing. The 

residents and their families that would move are already in the region and working at USAG-Miami. There would 

not be an increase in personnel working at USAG-Miami as a result of the MILCON Alternative.

The MILCON Alternative would have negligible, long-term adverse impacts on public services in Doral, Florida. 

Miami-Dade County would provide police, fire, and emergency services to the proposed housing development. 

Fire, police, and emergency services would be provided in the normal service area and would not unduly burden 

existing police, fire, or emergency services. 

The MILCON Alternative would have minor long-term adverse direct impacts on schools in Doral, Florida. Children 

of military personnel residing within the proposed housing development would likely attend local schools. Some

military families already live in Doral and have children who attend Doral schools; therefore, the relocation of 

these families to the proposed housing development would not impact school attendance in Doral. Any increase 

in students at schools in Doral because of the MILCON Alternative would be minor and able to be accommodated 

by the large number of school options in the area. 

The MILCON Alternative would have moderate long-term direct beneficial impacts on housing in the local area. As 

a result of the MILCON Alternative, military personnel would no longer have a need to rent or buy properties in 

Doral or its surrounding communities. Given the rapid population growth and the projected housing shortage 

(USAG-Miami, 2018) in the local area, having additional property vacancies would be beneficial to local 

community seeking housing in the vicinity of Doral. No long-term adverse indirect impacts to the housing market 

are anticipated from removing military personnel from the pool of property renters and buyers in the area. 
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

3-24

Because no immigration of people from outside the region would occur and only one new part-time job would be 

created, no induced growth from the MILCON Alternative would result.

3.12.2.2 EUL Alternative 

The EUL Alternative would have temporary minor to moderate beneficial impacts on economic development as a 

result of construction activities. There would be temporary construction employment and associated wages. In 

addition, local suppliers could experience a short-term increase in the demand for construction-related materials. 

These temporary beneficial impacts on economic development would be greater than the MILCON Alternative 

due to the additional construction of the mixed-use development. 

There would be long-term beneficial impacts on economic development due to the establishment of retail 

businesses and restaurant in the mixed-use development which would likely attract patrons in from the MiamiDade County area. While there may be some use by persons from outside the area, it is expected that this use 

would be incidental by visitors already in the area for other purposes and would not represent a change in the 

regional economy as nonresidents are unlikely to come to the EUL site specifically for the new development.

Because the metro Miami economy is very large, the EUL Alternative would have long-term minor to moderate 

beneficial impacts on economic development, which would more than offset the loss of the cattle operation.

Housing and maintenance hires would be from the local community, and the community center in the military 

housing development would likely be staffed by one part-time person from the region. The proposed mixed 

residential and commercial development in the southern portion of the acquired property would provide space 

for businesses to rent/buy and would create additional jobs in the local area, but no substantial movement of 

people from outside the area to staff these businesses would be expected.

There would be negligible long-term adverse economic impacts from the reduction in cattle production on the 

FAA parcel. The adverse economic impact of this small cattle operation is negligible within the context of the 

economy of the greater Miami area.

Adverse impacts to public services under the EUL Alternative would be greater than the MILCON due to additional 

patrons and residents with the larger development, but with the capacity of the area services, the level of impacts 

of the project would be similar to the MILCON Alternative (Section 3.12.2.1).

Under the EUL Alternative, impacts to housing described under the MILCON Alternative (Section 3.12.2.1) would 

occur. In addition, the proposed mixed-use development in the southern portion of the acquired property would 

create additional available residences in Doral, where vacant housing is limited due to population growth. The EUL 

Alternative would have a greater long-term direct beneficial impact on housing compared with the MILCON 

Alternative due to the creation of publicly available housing, but the impact would remain moderate.

Because no substantial immigration of people from outside the region would be expected, any induced growth 

from the EUL Alternative would be negligible.

3.12.2.3 No Action Alternative 

Under the No Action Alternative, there would be no change to the existing conditions described in Section 3.12.1. 

There would be no short-term or long-term beneficial impacts to economic development from the proposed 

construction or new commercial spaces. Military personnel would continue to live off-installation in communityprovided housing and potentially be unable to reach USAG-Miami in the required time during emergencies, which 

could impact mission readiness. Based on projected available housing units within a 20-mile commute radius and 

forecasted vacancy rates, there would be a shortfall of 318 homes (172 Family Housing Units and 146 

Unaccompanied Housing Units) by 2023 (USAG-Miami, 2018).
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

3-25

3.13 Coastal Zone Management

3.13.1 Affected Environment

The proposed project area is within the designated coastal zone in south Florida. However, the proposed project 

area is inland from the coastline and separated from the coastline by metropolitan Miami. 

3.13.2 Environmental Consequences 

3.13.2.1 MILCON Alternative 

USAG-Miami has evaluated the MILCON Alternative and found it to be consistent to the extent practicable with 

the enforceable policies of coastal zone management in Florida. USAG-Miami will submit a Coastal Zone Act 

Consistency Determination to the FDEP Coastal Management Program through the Florida State Clearinghouse at 

the same time the public notice is published (Appendix B). The Consistency Determination concludes that the 

Proposed Action is consistent to the extent practicable with the enforceable provisions of the Florida Coastal Zone 

Management Program. Statutes addressed as part of the Florida Coastal Zone Management Program consistency 

review and considered in the analysis of the Proposed Action are discussed in Appendix B. Potential impacts 

would be long-term and adverse because the proposed action consists of building permanent structures within 

the coast zone. Any impacts to coastal resources would be negligible because the proposed action remains 

consistent with the enforceable policies of Florida’s Coastal Zone Management Program (Appendix B).

Under the Proposed Action, there would be no indirect impacts to coastal zone resources addressed through 

Florida coastal zone management.

3.13.2.2 EUL Alternative 

The EUL Alternative would be consistent to the extent practicable with the enforceable policies of coastal zone 

management in Florida. USAG-Miami will submit a Coastal Zone Act Consistency Determination to the FDEP 

Coastal Management Program through the Florida State Clearinghouse at the same time the public notice is 

published (Appendix B). The Consistency Determination concludes that the Proposed Action is consistent to the 

extent practicable with the enforceable provisions of the Florida Coastal Zone Management Program. Statutes 

addressed as part of the Florida Coastal Zone Management Program consistency review and considered in the 

analysis of the Proposed Action are discussed in Appendix B. Any impacts to coastal resources would be 

comparable to those discussed for the MILCON Alternative (Section 3.13.2.1).

3.13.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.13.1 

would continue. There would be no impacts to coastal resources from the Proposed Action.

3.14 Safety and Occupational Health

3.14.1 Affected Environment

The Proposed Action would be implemented in compliance with all applicable federal laws, codes, and regulations 

and with all applicable laws, ordinances, codes, and regulations of the state of Florida and Miami-Dade County 

with regard to construction, health, safety, food service, water supply, sanitation, licenses and permits to do 

business, and all other matters.

The radar antenna on the FAA property will remain in use for the foreseeable future. This type of communications 

equipment produces radiofrequency (RF) radiation, which is in the electromagnetic frequency ranges of 3 

kilohertz to 300 megahertz. FAA assessed the risk from the operation of the radar and established a setback to 

protect human health. The area immediately around the antenna site, approximately 0.7 acre, is fenced to 

establish this safety setback and to deter unauthorized entry and accidental exposure to potentially harmful RF 
SECTION 3 – AFFECTED ENVIRONMENT AND CONSEQUENCES

3-26

radiation (Figure 3-1). No portion of the MILCON Alternative would be within the RF setback area or within 500 

feet of the RF setback area. 

FAA personnel who provide maintenance on the antenna, and work within the fenced in area, follow appropriate 

occupational safety procedures and employ appropriate personal protective equipment when conducting 

maintenance.

The FAA established additional setbacks at 853 feet, 929 feet, and 1,019 feet, which are to prevent interference 

with the radar antenna.

3.14.2 Environmental Consequences

3.14.2.1 MILCON Alternative 

Under the MILCON Alternative, proposed construction would have the potential for minor, short-term adverse 

direct impacts to health and safety. This includes the temporary presence of construction vehicles onsite. 

Appropriate safety plans and Occupational Safety and Health Administration (OSHA) regulations would be 

followed to limit the risk of accidents. 

The human body is most susceptible to absorption of electromagnetic frequencies between 30 and 

300 megahertz. Exposure can result in heating of the body and cataract formation in the lens of the eye. (FAA, 

2016). To produce adverse health effects, RF exposure above the threshold level must occur. The threshold level 

is the exposure needed to increase tissue temperature by at least 1 degree Celsius. There is no evidence that 

exposures to RF fields below threshold levels causes adverse health effects, including cancer (Word Health 

Organization, 2019). On the FAA parcel, the antenna has several standoff setbacks that restrict development by 

varying degrees. No housing would be constructed within the 853-foot-radius FAA established antenna standoff 

area to avoid interference with operation of the radar system; however, non-vertical assets such as stormwater 

retention infrastructure, roads, or parking may be located within this radius. Proposed structures between the 

853-foot radius and the 1,019-foot radius would be compliant with FAA requirements for those designated areas 

and would not interfere with operation of the radar. The FAA maintains posted signs and labels that identify the 

location of radiation hazards (FAA, 2016) and the antenna site would remain fenced to deter unauthorized entry

and subsequent exposure to RF from the antenna (Figure 3-1). No construction would occur within the RF 

radiation setback area and no housing or activity areas would be placed where exposure to dangerous radiation 

could occur. Areas around the antenna where dangerous radiation may be encountered are clearly marked and 

inaccessible to unauthorized personnel. Due to the distance of the proposed housing from the antenna and to the 

exclusion fencing around the antenna site, no adverse impacts resulting from exposure of construction workers or 

residents of the housing development to RF radiation associated with the FAA antenna would occur. FAA 

maintenance workers would continue to follow safety requirements of their job.

The housing development would be surrounded by a fence and construction of the proposed housing 

development would be confined to the project area; therefore, there would be no indirect impacts to safety and 

occupational health.

3.14.2.2 EUL Alternative 

Under the EUL Alternative, the impacts to safety and occupational health described for the MILCON Alternative 

(Section 3.14.2.1) would occur. In addition, the construction associated with the mixed-use development would 

increase the duration and amount of construction. The EUL Alternative would have a greater short-term adverse 

direct impact on safety and occupational health compared to the MILCON Alternative, not only from a larger 

development but also the longer construction duration. Impacts to health and safety would still be expected to be 

minor with implementation of safety plans and OSHA regulations. As with the MILCON Alternative, buildings and 

infrastructure associated with the mixed-use development would not be placed within the RF radiation setback 

area and no exposure to dangerous radiation would occur. Due to the distance of the proposed housing and 

mixed-use development from the antenna and to the exclusion fencing around the antenna site, no adverse 
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impacts resulting from the exposure of construction workers or tenants/patrons of the mixed-use development to 

RF radiation associated with the FAA antenna would occur.

3.14.2.3 No Action Alternative 

Under the No Action Alternative, no construction would occur. Existing conditions described in Section 3.14.1 

would continue. There would be no impacts to safety and occupational health from the Proposed Action.

3.15 Hazardous Materials

3.15.1 Affected Environment

The FAA parcel was assessed for hazardous materials and potential contamination and an Environmental 

Condition of Property (ECP) report was prepared (CH2M, 2017). Hazardous materials identified on the FAA 

property included a 1,000-gallon diesel tank, self-contained emergency generator, batteries, and buildings 

constructed before 1978 that may contain asbestos containing material and lead-based paint. No other hazardous 

materials or environmental conditions were identified on the FAA property (CH2M, 2017). 

3.15.2 Environmental Consequences

3.15.2.1 MILCON Alternative 

The MILCON Alternative would result in short-term negligible adverse direct impacts on hazardous materials and 

petroleum products from construction activities. Construction would require the use of hazardous materials such 

as gasoline, oils, coolant, and lubricants commonly used by construction equipment, paints, welding gases, 

solvents, preservatives, and sealants.
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Equipment servicing and repair activities could temporarily generate oily and hazardous wastes, such as spent 

solvents, residual fuels, used oils, used batteries, antifreeze, and filters. Construction activities would be 

conducted consistent with hazardous waste and pollution use and storage regulations, with guidelines specified in 

a Stormwater Pollution Prevention Plan (SWPPP). It is anticipated that the quantity of hazardous materials used 

during construction activities would be minimal and their use would be of short duration. Contractors would be 

responsible for the management of hazardous materials, which would be handled in accordance with federal and 

state regulations. BMPs documented in an SWPPP and/or a project-specific site construction safety plan would be 

followed to avoid significant risks or health hazards associated with the use of hazardous materials and hazardous 

waste generation and disposal. Short-term adverse direct effects from the use of hazardous and toxic substances 

during construction would be negligible with the use of BMPs. There would be negligible short-term adverse 

indirect impacts on hazardous materials with the use of BMPs and the SWPPP. Implementation of the MILCON 

Alternative would not impact any of the hazardous materials or buildings identified on the FAA parcel by the ECP 

report (CH2M, 2017). These buildings and materials would be within the secure FAA area and would be 

inaccessible to unauthorized personnel. 

3.15.2.2 EUL Alternative 

Under the EUL Alternative, the types of impacts to hazardous materials described for the MILCON Alternative 

(Section 3.15.2.1) would occur over a larger area, 107.5 acres. In addition, the construction associated with the 

mixed-use development would increase the amount of hazardous materials and petroleum products used. The 

EUL Alternative would have a greater impact to hazardous materials compared to the MILCON Alternative, not 

only from a larger development but also the longer construction duration. However, with proper management 

and implementation of BMPs documented in an SWPPP and/or a project-specific site construction safety plan, 

adverse direct and indirect impacts on hazardous materials would be short-term and negligible.

3.15.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.15.1 

would continue. There would be no impacts to hazardous materials from the Proposed Action.

3.16 Traffic and Transportation

3.16.1 Affected Environment

The City of Doral has created a Traffic Relief Management Plan to help alleviate high levels of congestion on its 

major roads (City of Doral, 2019d). Efforts to improve traffic flow include updating traffic signal timing, monitoring 

traffic conditions in real-time to be able to recommend additional traffic signal updates, and evaluating 

improvements to provide additional capacity at signalized intersections. 

The 160-acre parcel is bounded by NW 33rd Street on the north, NW 92nd Avenue on the east, NW 25th Street on 

the south, and NW 97th Avenue on the west (Figure 1-1). These are all paved, four-lane roads (two lanes in each 

direction) with turn lanes. There are traffic lights at the intersections of NW 33rd Street and NW 97th Avenue and 

at the intersections of NW 25th Street and NW 97th Avenue. There are stop signs at the other two intersections. 

There are public bus stops along NW 97th Avenue and NW 25th Street and sidewalks along both sides of all four 

roads except the western side of NW 92nd Avenue and the northern side of NW 25th Street. Average Annual Daily 

Traffic in 2018 was 12,800 in both directions along NW 33rd Street, 19,900 in both directions along NW 97th

Avenue, and 33,500 in both directions along NW 25th Street (FDOT, 2019). Data for NW 92nd Avenue was not 

available.

3.16.2 Environmental Consequences

3.16.2.1 MILCON Alternative 

Under the MILCON Alternative, there would be a short-term moderate adverse direct impact on traffic during 

construction of the connector road between the housing development and the SOUTHCOM headquarters. During 
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this time, a portion of NW 33rd Street would need to be closed and detours around the construction area would 

be required. To the extent practicable, a single lane of traffic and a team to direct traffic would be provided to 

limit the impacts to local traffic. The construction contractor would obtain the necessary permits required to 

complete the connector road and the elevation of NW 33rd Street. 

There would be short-term minor adverse direct impacts on traffic from an increase in construction and personal 

vehicles along local roads during construction of the housing development. Fill would be brought to the parcel via 

dump trucks. This would add to local traffic during the early stages of the site development. Heavy equipment, 

such as graders and pavers, would be stored on the 160-acre parcel while being used, rather than being brought 

in daily.

The increase in construction-related traffic generated by the proposed project and construction of the pedestrian 

walkway beneath NW 33rd Street could have a minor short-term adverse direct impact on emergency vehicle 

response times. 

Under the MILCON Alternative, there would be long-term minor adverse direct impacts on local traffic from an 

increase in personal vehicle use by residents of the new housing development. Traffic between the housing 

development and SOUTHCOM headquarters would follow the connector road under NW 33rd Street and would 

not impact local traffic. There would be a negligible long-term beneficial impact to regional traffic because 

SOUTHCOM personnel would not need to commute through local roads to work.

3.16.2.2 EUL Alternative 

Under the EUL Alternative, the types of impacts to traffic and transportation described for the MILCON 

Alternative (Section 3.16.2.1) would occur for a larger area, 107.5 acres. The EUL Alternative would have a greater 

adverse impact on traffic and transportation compared to the MILCON Alternative. There would also be additional

impacts from construction and operation of the mixed-use development and the longer construction duration. 

Heavy equipment, such as graders and pavers, would be stored on the site while being used, rather than being 

brought in daily. No lane closures or other disruptions to circulation patterns would be required for construction. 

No activities that would create traffic hazards are anticipated. Adverse traffic impacts from the construction of the 

mixed-use development would be short-term, direct and minor.

Under EUL Alternative, there could be long-term minor adverse direct impacts on traffic from an increase in 

vehicles on local roads from the use of the new mixed-use development by residents and patrons of the 

businesses, but there also could be a long-term beneficial direct impact on regional roads as services are provided 

closer to where people live, which would reduce overall traffic.

3.16.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.16.1 

would continue. There would be no impacts to traffic or transportation from the Proposed Action.

3.17 Recreation

3.17.1 Affected Environment

There are no recreational facilities on the 160-acre parcel. The 82-acre Doral Central Park is east of the northern

portion of the 160-acre parcel across NW 92nd Avenue. The park includes a walking and jogging trail, an exercise 

station, grills, and picnic benches (City of Doral, 2019e). The Beacon Trail is a 1.2-mile asphalt trail within the canal 

easement along the northern side of NW 25th Street between NW 97th Avenue and NW 107th Avenue (Rails to 

Trails, 2019). 

The City of Doral prepared a Bicycle Network Plan in 2015 which shows the full proposed route of the Beacon Trail 

running from State Route 821 along the northern side of NW 25th Street (and along the southern portion of the 

162-acre parcel) to State Route 826 Palmetto Expressway (Kimley-Horn and Associates, 2015). The City of Doral 

Parks System Master Plan recommends linking the Doral Central Park with the Beacon Trail by connecting the two 
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south along NW 92nd Avenue to NW 25th Street (Browning Day, Mullins, Dierdorf, 2018). The City of Doral Parks 

System Master Plan also recommends adding a bicycle and walking path along NW 33rd Street west of Doral 

Central Park as a pilot project for the City’s connectivity vision (Browning Day, Mullins, Dierdorf, 2018).

3.17.2 Environmental Consequences

3.17.2.1 MILCON Alternative 

Under the MILCON Alternative, there would be no direct impacts to recreation because there are no recreational 

facilities on the parcel. Entry and exits from the housing development would not interfere with access to the Doral 

Central Park because access to the park is from NW 87th Avenue, east of the park. The construction contractor 

would coordinate with the City of Doral during the planning and construction phases to avoid or minimize 

scheduling and other impacts to any planned recreation-related construction projects ongoing in the area.

Under the MILCON Alternative, there could be negligible long-term indirect adverse impacts to recreation from 

the increased use of Doral Central Park by new local residents from housing construction. The proposed 

construction would not prohibit the future expansion of the Beacon Trail as proposed in the 2015 Bicycle Network 

Plan (Kimley-Horn and Associates, 2015). The Beacon Trail expansion could still be constructed within the canal 

easement. 

3.17.2.2 EUL Alternative 

Under the EUL Alternative, there would be no direct impacts to recreation because there are no recreational 

facilities on the parcel.

Under the EUL Alternative, the types of impacts to recreation described for the MILCON Alternative (Section 

3.17.2.1) would occur over a larger area, 107.5 acres. In addition, there could be long-term minor indirect adverse

impacts to recreation from the increased use of Doral Central Park by new residents moving into housing 

constructed under the EUL. The EUL Alternative would have a greater indirect impact on recreation compared to 

the MILCON Alternative, from the larger development, more residents, and persons from outside the area 

patronizing the commercial development. With increased use of the recreation system, impacts are anticipated to 

be minor. The proposed construction would not prohibit the future expansion of the Beacon Trail as proposed in 

the 2015 Bicycle Network Plan (Kimley-Horn and Associates, 2015). The Beacon Trail expansion could still be 

constructed within the canal easement.

3.17.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.17.1 

would continue. There would be no impacts to recreation from the Proposed Action.

3.18 Utilities

3.18.1 Affected Environment

3.18.1.1 Potable Water 

The Biscayne aquifer is the primary drinking water source for Miami-Dade County and, therefore, the subject 

property. The Biscayne aquifer supplies water to more than 5 million residents in Miami-Dade, Broward, and 

southern Palm Beach counties and is the most intensely used water source in Florida (SFWMD, 2019). MiamiDade WASD supplies potable drinking water to the area through county supply lines. The only active water lines 

are present in the far northeastern portion of the FAA property at the Florida National Guard facility and in the 

central portion of the property, providing water to the Miami-Dade Fire Rescue Department building (CH2M, 

2017).
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3.18.1.2 Wastewater System 

Wastewater treatment and disposal for the FAA parcel is provided by Miami-Dade WASD. The Miami-Dade WASDoperated South District Wastewater Treatment Plant treats wastewater from the FAA property (CH2M, 2017).

3.18.1.3 Stormwater 

The City of Doral receives stormwater from heavy rainfall, tropical storms, and hurricanes. Three secondary canals 

are located within the city and they are operated and maintained by Miami-Dade County and the South Florida 

Water Management District. The purpose of maintaining the canals is to avoid flooding events (CH2M, 2017). 

The North Line Canal is located south of and adjacent to the subject property and runs along NW 25th street from 

State Route 826 to the Florida Turnpike. The subject property lies within a FEMA-defined Special Flood Hazard 

Area (FEMA, 2009). Because the subject property is adjacent to a canal and within a Special Flood Hazard Area, 

strong storm events have the potential to exceed the designs of the canals (CH2M, 2017).

3.18.1.4 Energy Sources 

Electric service is provided by Florida Power and Light. Natural gas is provided by Florida City Gas and TECO 

Peoples Gas (Potomac-Hudson Engineering, 2006).

3.18.1.5 Solid Waste 

Solid waste in Doral, Florida is currently handled by several franchised, private haulers. In addition, the MiamiDade County Solid Waste Management has neighborhood trash and recycling centers for self-disposal of waste 

(City of Doral, 2019f). Two landfills, North Dade Landfill and South Dade Landfill, are available in Miami-Dade 

County for permitted private haulers, municipal waste haulers, and permitted landscapers. The North Dade 

Landfill has two cells, with only one currently accepting trash. Disposal capacity at the North Dade Landfill is 

anticipated to last through 2020. The South Dade Landfill has five cells, three of which have been filled and closed. 

The fourth cell is active, and construction of the fifth cell is underway (Miami-Dade County, 2019b). 

3.18.2 EnvironmentalConsequences

3.18.2.1 MILCON Alternative 

Short-term minor direct adverse impacts on utilities would be expected from the MILCON Alternative during 

construction. Short-term interruptions could occur when buildings are disconnected from or connected to 

utilities. Interruptions in services would be coordinated with area users prior to disconnection, to the extent 

practicable. Existing utilities in and near the construction footprint would be identified in advance of construction 

to limit impacts.

Long-term negligible to minor direct adverse impacts on utility systems would be expected from the MILCON 

Alternative because the demand for utility services from the new housing units and associated facilities would be 

relocated from within the region and not a new demand. New buildings would require expansion of existing utility 

delivery to provide service, but there would be no change in infrastructure capacity. New housing would be 

energy efficient and would likely require less energy than the housing currently accommodating personnel.

Energy supply, water supply, and wastewater treatment capacity are sufficient to accommodate the increased 

demand resulting from the new structures.

A stormwater permit from the SFWMD would be obtained prior to construction activities. With implementation of 

construction stormwater controls, the increase in stormwater discharge during construction would be minimized. 

Further, because appropriate post-construction stormwater controls would be included in the design, any 

increase in stormwater discharge resulting from operation of the MILCON Alternative would be limited to events 

that exceed the design storm for the post-construction stormwater controls. These increases in stormwater runoff 

would not exceed the capacity of the local stormwater conveyance system and any adverse indirect impacts on 

the stormwater system would be short-term and negligible. 
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The MILCON Alternative would result in a short-term minor adverse direct impact to solid waste from an increase 

in construction debris. Solid waste generated from the proposed construction activities would consist of building 

materials such as solid pieces of concrete, metals, and lumber. Contractors would be required to recycle 

construction debris to the maximum extent practicable in accordance with installation policy, thereby diverting it 

from landfills. 

The MILCON Alternative would result in a long-term minor adverse direct effect to solid waste by permanently 

using landfill capacity for the disposal of nonrecyclable construction debris. Solid waste generated by occupants of 

the housing development would not change the future quantity of solid waste generated compared to existing 

levels. Residents of the housing development would be relocating from within the County where they are already 

using solid waste disposal and landfill resources. 

Under the MILCON Alternative, utility use by permanent residents in military housing would result in negligible

indirect adverse impacts on local utilities from an increase in demand because the demand would just be 

relocated from within the region.

3.18.2.2 EUL Alternative 

Under the EUL Alternative, impacts to utilities described under the MILCON Alternative (Section 3.18.2.1) would

occur. In addition, there would be additional demand related to the EUL development. Compared to the MILCON 

Alternative, there would be minor long-term increases in utility demand and waste disposal due to the proposed 

mixed residential and commercial development that would be constructed in the southern portion of the 

acquired parcel. However, the capacity of supply systems and regional facilities would be sufficient to 

accommodate this increase and overall adverse direct impacts would be negligible considering these resources 

serve approximately 2.8 million people in Miami-Dade County (U.S. Census Bureau, 2018b). There could also be an 

increase in utility outages associated with connecting new buildings to supply systems resulting in a short-term 

minor adverse direct impact.

3.18.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.18.1 

would continue. There would be no impacts to utility infrastructure or service from the Proposed Action.

3.19 Visual Resources

3.19.1 Affected Environment

The parcel is an open grassy field with an FAA radar and associated vacant buildings in the center. An access road 

runs from NW 25th Street to the center of the parcel. Several rows of trees run north to south on the western side 

of the parcel. The site is used as a cow pasture and includes several sheds and farm equipment. There are barbed 

wire fences across the site to keep the cows out of the radar area. Existing development surrounds the parcel with 

the exception of Doral Central Park to the east of the parcel.

3.19.2 Environmental Consequences

3.19.2.1 MILCON Alternative 

The MILCON Alternative would result in moderate, short-term adverse direct impacts to visual resources during 

construction. Adverse impacts to visual resources could occur from stockpiles of materials, construction vehicles 

onsite, and partially constructed buildings. These impacts would be temporary and would end after completion of 

the construction activities.

The MILCON Alternative would result in moderate, long-term adverse direct impacts to visual resources because 

of the changes associated with an undeveloped area becoming a developed site. After construction, the views 

into the site on the north would be of a residential area consistent with the area west of the parcel.
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3.19.2.2 EUL Alternative 

Under the EUL Alternative, the impacts to visual resources described for the MILCON Alternative (Section 

3.19.2.1) would occur in addition to adverse impacts from construction and operation of the mixed-use 

development. Short-term moderate adverse direct impacts to visual resources on the southern portion of the site 

would be similar to those on the northern portion of the parcel. 

The EUL Alternative would result in moderate, long-term adverse direct impacts to visual resources because of the 

changes associated with an undeveloped area becoming a developed site. After construction, the views into the 

site on the north would be of a residential area consistent with the area west of the parcel and views into the site 

on the south would be of a retail area consistent with the area south of the site across NW 25th Street.

3.19.2.3 No Action Alternative 

Under the No Action Alternative, no development would occur. Existing conditions described in Section 3.19.1 

would continue. There would be no impacts to visual resources from the Proposed Action.
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Cumulative Impacts

4.1 Introduction

As defined in 40 CFR 1508.7 (CEQ Regulations), a cumulative effect is the “impact on the environment which 

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

future actions regardless of what agency (federal or non-federal) or person undertakes such other actions.”

Principles of cumulative effects analysis are described in the CEQ guide, Considering Cumulative Effects under the 

National Environmental Policy Act. CEQ guidance on cumulative impacts analysis states: 

For cumulative effects analysis to help the decision-maker and inform interested parties, it must be limited 

through scoping to effects that can be evaluated meaningfully. The boundaries for evaluating cumulative 

effects should be expanded to the point at which the resource is no longer affected significantly or the effects 

are no longer of interest to affected parties. (CEQ, 1997)

This section addresses the potential for cumulative impacts resulting from interaction of the Proposed Action with 

other past, present, and reasonably foreseeable actions occurring at USAG-Miami and in the surrounding 

community.

4.1.1 Projects Identified with the Potential for Cumulative Effects

Projects identified with potential for cumulative effects with the Proposed Action include the following:

• Development of Doral Central Park (estimated FY 2020) – construction and operation of a 75,000-plus squarefoot indoor recreation center, outdoor aquatics complex, large parking structure, waterfront promenade and 

event pavilion, playgrounds, multi-use sports and athletic fields, and other features at Doral Central Park.

Doral Central Park is located immediately east of the proposed project area.

• Doral Cultural Arts Center (estimated FY 2020) – construction and operation of a large art gallery space with 

associated indoor and outdoor facilities at Downtown Doral Park. Downtown Doral Park is approximately 1.4 

miles northeast of the proposed project area.

• Jackson West Medical Center (FY 2019-2020) – construction and operation of a 275,000-square-foot facility

that will include a 100-bed hospital (José Milton Memorial Hospital). The Jackson West Medical Center is 

approximately 1.3 miles east of the proposed project area.

• Bicycle/Pedestrian Walkway across Doral Boulevard (FY 2021–2022) – construction of a pedestrian/wildlife 

overpass. 

4.2 Land Use

4.2.1 MILCON Alternative

There is a limited amount of open space in the vicinity of the proposed project area. Under the MILCON 

Alternative, developing the FAA parcel would result in a loss of open space and pasture available for grazing but 

would be consistent with the existing land use. In combination with the development of the adjacent Doral 

Central Park, the MILCON Alternative would have a moderate cumulative impact on loss of open space in the local 

area. No other known development would affect grazing in the local area. There would be moderate cumulative 

impacts on pasture in the local area under the MILCON Alternative.
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4.2.2 EUL Alternative

Under the EUL Alternative, the amount of converted pastureland would be greater than for the MILCON 

Alternative (Section 4.2.1) due to the greater loss of open space from the development of the southern portion of 

the parcel. Because of the small total area involved, cumulative impacts on loss of open space in the local area 

would be moderate and there would be moderate cumulative impacts on pasture under the EUL Alternative.

4.2.3 No Action Alternative

Under the No Action Alternative, open space and available pasture would remain. There would be no cumulative 

impacts to soils associated with projects identified in Section 4.1.1.

4.3 Soils

4.3.1 MILCON Alternative

Moderate soil disturbance would result from construction and clearing activities of up to 75 acres associated with 

the MILCON Alternative. Increased erosion following soil disturbance from grading and excavation to support 

construction could contribute to cumulative impacts to soils when combined with potential impacts from other 

local projects that may be implemented. Such impacts are expected to be less than significant because these 

projects are localized and because project development would be expected to comply with Miami-Dade County 

requirements for stormwater control and implementation of BMPs. 

4.3.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to soils described for the MILCON Alternative (Section 4.3.1) 

would occur. In addition, there would be cumulative impacts to soils from construction of the mixed-use 

development. Overall, cumulative impacts to soils are expected to be less than significant, because project 

development would be expected to comply with Miami-Dade County requirements for stormwater control and 

implementation of BMPs.

4.3.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

soils associated with projects identified in Section 4.1.1.

4.4 Groundwater

4.4.1 MILCON Alternative

Implementation of the MILCON Alternative would have a negligible impact on groundwater with the 

implementation of BMPs. The Biscayne aquifer that underlies the project area provides drinking water for over 5 

million people across multiple counties in southeastern Florida. The impacts on aquifer recharge from an increase 

in impervious surface area from development of the MILCON Alternative are small compared to the size of this 

aquifer, 50 acres versus 4,000 square miles. Less than significant cumulative impacts to groundwater would be 

anticipated from interaction of the MILCON Alternative with other past, present, and reasonably foreseeable 

projects.

4.4.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to groundwater described for the MILCON Alternative (Section 

4.4.1) would occur. While there would be additional construction associated with the mixed-use development, 

the intensity of cumulative impacts to groundwater from the EUL Alternative would be slightly greater than those 

described for the MILCON Alternative (Section 4.4.1), approximately 82 acres versus 4,000 square miles. Less than 
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4-3

significant cumulative impacts to groundwater would be anticipated from interaction of the EUL Alternative with 

other past, present, and reasonably foreseeable projects.

4.4.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

groundwater associated with projects identified in Section 4.1.1.

4.5 Surface Water

4.5.1 MILCON Alternative

The MILCON Alternative would not encroach upon any surface waters. Impacts from site runoff could interact 

with other projects; however, appropriate BMPs would be used to minimize site runoff from reaching nearby 

surface waters. Less than significant cumulative impacts to surface waters from interaction of the MILCON 

Alternative with other past, present, and reasonably foreseeable projects would likely occur.

4.5.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to surface water described for the MILCON Alternative 

(Section 4.5.1) would occur. While there would be additional construction associated with the mixed-use 

development, the intensity of cumulative impacts to surface water from the EUL Alternative would be slightly 

greater to those described for the MILCON Alternative (Section 4. 5.1) with implementation of BMPs. 

4.5.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

surface water associated with projects identified in Section 4.1.1.

4.6 Water Quality

4.6.1 MILCON Alternative

Appropriate BMPs would be implemented to minimize sedimentation and stormwater runoff. Post-construction 

stormwater management features would be constructed to minimize an increase in stormwater runoff once the 

housing is built. No cumulative impacts to water quality from interaction of the MILCON Alternative with other 

past, present, and reasonably foreseeable projects would likely occur.

4.6.2 EUL Alternative

Under the EUL Alternative, there would be additional construction associated with the mixed-use development; 

however, cumulative impacts to water quality would still be comparable to the MILCON Alternative (Section 4.6.1)

with implementation of BMPs and stormwater controls.

4.6.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There could be minor cumulative impacts to 

surface water quality from the interaction of site runoff from the development of Doral Central Park and organic 

loading associated with cattle grazing on the FAA parcel.
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4.7 Flood Hazards

4.7.1 MILCON Alternative

Impacts to the flood hazard area from the MILCON Alternative would be limited to the project area. In this area, 

flooding typically results from surge associated with storm events and not overbank events. The area does not 

appreciably function for flood storage or flood conveyance and would not interact with other developments to 

increase flood risk. Increased impervious surfaces associated with development have the potential to affect 

flooding rates. The increase in impervious surface under this alternative would have a less than significant indirect 

effect on flood hazard area because the stormwater controls would minimize runoff increase. In addition, the EUL

project area, which is greater than the MILCON Alternative, would be less than 0.1 percent of the surrounding 

area and would result in less than 0.01 inch in rise of floodwater in the region. Projects identified in Section 4.1.1 

would also be required to comply with stormwater regulations. Therefore, minor cumulative impacts to the flood 

hazard area from interaction of the MILCON Alternative with other past, present, and reasonably foreseeable 

projects would occur. 

4.7.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to the flood hazard area described for the MILCON Alternative 

(Section 4.7.1) would occur. While there would be additional construction associated with the mixed-use 

development, the intensity of cumulative impacts to the flood hazard area from the EUL Alternative would be 

slightly greater than those described for the MILCON Alternative (Section 4.7.1) with implementation of BMPs. 

4.7.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

the flood hazard area associated with projects identified in Section 4.1.1.

4.8 Air Quality

4.8.1 MILCON Alternative

Air quality impacts associated with construction of the MILCON Alternative would be minor and temporary. There 

could be incremental additions of dust from land disturbance associated with implementing the MILCON 

Alternative and unrelated planned or potential projects. Appropriate BMPs, as described in Section 3.8.3.1, would 

be implemented to minimize dust generation, as appropriate. There also would be minor short-term localized 

increases in combustion engine emissions from equipment operation during construction, but these would not be 

expected to result in exceedances of air quality standards and cumulative impacts on air quality are expected to 

be less than significant.

4.8.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to air quality described for the MILCON Alternative (Section 

4.8.1) would occur. There would be a minor increase in cumulative effects to air quality from the additional 

construction and operation of the mixed-use development compared to the MILCON Alternative. However, with 

implementation of BMPs, these would not be expected to result in exceedances of air quality standards and 

cumulative impacts on air quality are expected to be less than significant.

4.8.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to air 

quality associated with projects identified in Section 4.1.1.
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4.9 Noise

4.9.1 MILCON Alternative

The MILCON Alternative could result in moderate cumulative effects to construction-related noise in the local 

area when added to other planned projects in the area. After construction of the proposed housing development 

is complete, construction noise would cease and noise from the parcel would be consistent with noise from 

adjacent parcels. No significant cumulative impacts to noise are expected.

4.9.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to noise described for the MILCON Alternative (Section 4.9.1) 

would occur. There would be a minor increase in noise associated with construction of the mixed-use 

development. However, the cumulative noise levels would still be less than significant, especially when 

considering that construction of the projects identified in Section 4.1.1 may not occur simultaneously with

construction of the EUL Alternative and that not all projects are close enough for noise effects to combine.

4.9.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

noise associated with projects identified in Section 4.1.1.

4.10 Biological Resources

4.10.1 MILCON Alternative

The proposed project area is surrounded by urban development and contains low-quality habitat for wildlife. 

Special-status wildlife species are not known to occur within the proposed project area. Minor cumulative impacts 

to wildlife would result from interaction of the MILCON Alternative with other past, present, and reasonably 

foreseeable projects.

Minor impacts to vegetation would result from clearing and grading associated with construction of the MILCON 

Alternative. Special-status or rare plant species are not known to occur within the proposed project area and 

negligible cumulative impacts to vegetation would result from interaction of the MILCON Alternative with other 

past, present, and reasonably foreseeable projects.

4.10.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to biological resources described for the MILCON Alternative 

(Section 4.10.1) would occur. There would be an increase in the size and duration of construction compared to the 

MILCON Alternative from the mixed-use development. However, cumulative effects to biological resources are 

still expected to be less than significant (Section 4.10.1).

4.10.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

biological resources associated with projects identified in Section 4.1.1.
SECTION 4 – CUMULATIVE IMPACTS

4-6

4.11 Cultural Resources

4.11.1 MILCONAlternative

No cultural resources would be impacted by the project because none are present. Therefore, no cumulative 

impacts to cultural resources would be anticipated from interaction effects of the MILCON Alternative with other 

past, present, and reasonably foreseeable projects.

4.11.2 EUL Alternative

Under the EUL Alternative, cumulative impacts to cultural resources would be identical to the MILCON Alternative 

(Section 4.11.1).

4.11.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

cultural resources associated with projects identified in Section 4.1.1.

4.12 Socioeconomic Resources

4.12.1 MILCON Alternative

The MILCON Alternative would result in minor to moderate beneficial cumulative effects to economic 

development in the region. Cumulative benefits would derive from construction employment and associated 

wages and increased sales of construction-related materials. In the event multiple construction projects are 

occurring simultaneously in the area, the MILCON Alternative would contribute to adverse cumulative effects on 

emergency vehicle response times. Minor adverse impacts on emergency vehicle response times would end with 

construction and therefore be less than significant. There would be minor adverse cumulative impacts to schools

and housing and moderate cumulative effects to cattle grazing in the local area from the interaction of the 

MILCON Alternative with projects identified in Section 4.1.1. 

With both positive and negative cumulative effects, the net cumulative effect to socioeconomic resources would 

be minor and adverse.

4.12.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to socioeconomic resources described for the MILCON 

Alternative (Section 4.12.1) would occur. In addition, due to the construction and operation of the mixed-used 

development, cumulative impacts to socioeconomic resources would be greater than for the MILCON Alternative

(Section 4.12.1). The net cumulative effect on socioeconomic resources for the EUL Alternative would be minor 

and beneficial due to the greater benefit of the mixed-use development. 

4.12.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

socioeconomic resources associated with projects identified in Section 4.1.1.

4.13 Coastal Zone Management

4.13.1 MILCON Alternative

Per the Coastal Zone Act Consistency Determination prepared for this project (Appendix B) under the MILCON 

Alternative, impacts to coastal zone resources would be no more than negligible. Because there would be no 
SECTION 4 – CUMULATIVE IMPACTS

4-7

offsite effects and because there would be no loss of coastal resources, any cumulative impacts to coastal zone 

management from interaction with other past, present, and reasonably foreseeable projects would be negligible.

4.13.2 EUL Alternative

Under the EUL Alternative, cumulative impacts to coastal zone resources would be comparable to the MILCON 

Alternative (Section 4.13.1).

4.13.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

coastal zone management associated with projects identified in Section 4.1.1.

4.14 Safety and Occupational Health

4.14.1 MILCON Alternative

The MILCON Alternative would result in short-term construction hazards to construction workers that would be 

addressed through construction safety plans. There would be no adverse effects from exposure to RF radiation. 

Minor cumulative impacts to safety and occupational health would result from interaction of the MILCON 

Alternative with other past, present, and reasonably foreseeable projects.

4.14.2 EUL Alternative

Under the EUL Alternative, impacts to safety and occupational health would be comparable to the MILCON 

Alternative (Section 4.14.1). As with the MILCON Alternative, minor cumulative impacts to safety and 

occupational health would be expected.

4.14.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

safety and occupational health associated with projects identified in Section 4.1.1.

4.15 Hazardous Materials

4.15.1 MILCON Alternative

Construction and demolition projects could have the potential for an incremental increase in generation of 

hazardous wastes. With proper handling and disposal of hazardous materials, the potential for cumulative

impacts to hazardous materials resulting from interaction of the MILCON Alternative with other past, present, and 

reasonably foreseeable projects would be negligible.

4.15.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to hazardous materials described for the MILCON Alternative 

(Section 4.15.1) would occur. There would be slightly more hazardous waste generated compared to the MILCON 

Alternative from construction of the mixed-use development. However, with proper disposal and handling of 

hazardous materials, cumulative effects to hazardous materials would be negligible.

4.15.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

hazardous materials associated with projects identified in Section 4.1.1.
SECTION 4 – CUMULATIVE IMPACTS

4-8

4.16 Traffic and Transportation

4.16.1 MILCON Alternative

The MILCON Alternative could result in cumulative effects to construction-related traffic on or around the parcel if 

multiple construction projects were to occur at the same time. There could also be cumulative adverse impacts on 

local traffic if construction hours overlap with rush hour. These impacts would not be significant because most 

heavy equipment would be stored onsite during construction, and related traffic would end once construction is 

complete. 

The MILCON Alternative could result in minor cumulative effects to local traffic from an increase in personal 

vehicle use by residents of the new housing development. However, traffic between the housing development 

and SOUTHCOM headquarters would follow the connector road under NW 33rd Street and would not contribute 

to local traffic.

4.16.2 EUL Alternative

Under the EUL Alternative, the cumulative effects to traffic described for the MILCON Alternative (Section 4.16.1)

would occur. The EUL Alternative could also result in long-term, minor to moderate cumulative effects to traffic 

on and around the parcel from the residents and visitors of the mixed-use development. Efforts by the City of 

Doral to ease traffic congestion, as specified in the Traffic Relief Management Plan (City of Doral, 2019d), would 

help to minimize the traffic impacts. No significant cumulative impacts to traffic and transportation are expected.

4.16.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

traffic associated with projects identified in Section 4.1.1.

4.17 Recreation

4.17.1 MILCON Alternative

The MILCON Alternative could have impacts to recreation from the increased use of Doral Central Park by new 

local residents and guests associated with the proposed newly constructed military housing units. Minor 

cumulative impacts could occur if there is an increase in persons who move into the area and use the new Doral 

Central Park facilities or if visitors to the Jackson West Medical Center or the Doral Cultural Arts Center also use 

the Doral Central Park facilities. 

4.17.2 EUL Alternative

Under the EUL Alternative, cumulative impacts to recreation described for the MILCON Alternative (Section 

4.17.1) would occur. Cumulative impacts to recreation may be higher compared to the MILCON Alternative 

(Section 4.17.1) from additional residents of the mixed-use development; however, cumulative impacts would still 

be less than significant.

4.17.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

recreation associated with projects identified in Section 4.1.1.
SECTION 4 – CUMULATIVE IMPACTS

4-9

4.18 Utilities

4.18.1 MILCON Alternative

The incremental impact of the MILCON Alternative when combined with other past, present, and reasonably 

foreseeable projects would increase the demand on local utilities. The housing units currently occupied by USAGMiami personnel would become available on the market and some of these units likely would be occupied by 

people within the region. It is unlikely that people from outside the region would relocate to the region because 

of the availability of this housing, but rather would take advantage of the available housing market upon moving 

to the region. Because residents associated with military housing would be relocated from within the region and 

would not represent a new demand on utility services, cumulative effects to utilities would be minor. The 

increased demand from the Proposed Action combined with the demand from the Jackson West Medical Center 

and the other actions identified in Section 4.1.1 would have a potential moderate adverse cumulative impact on 

utilities; however, the increase in utility demand would be within the regional capacity.

4.18.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to utilities described for the MILCON Alternative (Section 

4.18.1) would occur. There would be additional demand on local utilities associated with the mixed-use 

development that would interact with other past, present, and reasonably foreseeable projects. The increased 

demand would have a less than significant cumulative impact on utilities because the increase in utility demand 

would be within the regional capacity.

4.18.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

utilities associated with projects identified in Section 4.1.1.

4.19 Visual Resources

4.19.1 MILCON Alternative

When considered cumulatively, impacts to visual resources from the construction of the proposed housing 

development and other planned projects would be moderate but less than significant. The view from outside the 

parcel would change from open space to new buildings. However, the views would be consistent with the existing 

views of the surrounding area. Therefore, no significant cumulative impacts to visual resources are expected.

4.19.2 EUL Alternative

Under the EUL Alternative, the cumulative impacts to visual resources described for the MILCON Alternative 

(Section 4.19.1) would occur. In addition, there would be a greater loss of open space from the development of 

the southern portion of the FAA parcel; however, views would still be consistent with the existing views of the 

surrounding area and no significant cumulative impacts to visual resources are expected.

4.19.3 No Action Alternative

Under the No Action Alternative, existing conditions would continue. There would be no cumulative impacts to 

visual resources associated with projects identified in Section 4.1.1.
SECTION 5

5-1

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for South Florida. https://www.fws.gov/verobeach/MSRPPDFs/Garbers.PDF. Accessed on September 1, 2019.

U.S. Fish and Wildlife Service (USFWS). 1999d. Okeechobee Gourd Cucurbita okeechobeensis ssp. okeechobeensis. 

Multi-Species Recovery Plan for South Florida. https://www.fws.gov/verobeach/MSRPPDFs/Okeechobee.PDF. 

Accessed on September 4, 2019.

U.S. Fish and Wildlife Service (USFWS). 1999e. Everglade Snail Kite Rostrhamus sociabilis plumbeus. Multi-Species 

Recovery Plan for South Florida. https://www.fws.gov/verobeach/MSRPPDFs/EvergladeSnailKite.pdf. Accessed on 

September 5, 2019.

U.S. Fish and Wildlife Service (USFWS). 1999f. Florida Grasshopper Sparrow Ammodramus savannarum floridanus. 

Multi-Species Recovery Plan for South Florida. 

https://www.fws.gov/verobeach/MSRPPDFs/FloridaGrasshopperSparrow.pdf. Accessed on September 5, 2019.

U.S. Fish and Wildlife Service (USFWS). 1999g. Stock Island Tree Snail Orthalicus reses. Multi-Species Recovery 

Plan for South Florida. https://www.fws.gov/verobeach/MSRPPDFs/StockIslandTreeSnail.pdf. Accessed on 

September 5, 2019.

U.S. Fish and Wildlife Service (USFWS). 2015a. Endangered and Threatened Wildlife and Plants; Endangered 

Species Status for Chamaecrista Lineata Var. Keyensis (Big Pine Partridge Pea), Chamaesyce Deltoidea ssp. 

serphyllum (Wedge Spurge), and Linum Arenicola (Sand Flax), and Threatened Species Status for Argythamnia 

Blodgettii (Blodgett’s Silverbush); Proposed Rule. Federal Register Vol. 80 No. 188, 58536 – 58567.

U.S. Fish and Wildlife Service (USFWS). 2015b. Status of the Species - Bartram’s scrub hairstreak butterfly 

(Strymon acis bartrami). October. 

https://www.fws.gov/verobeach/StatusoftheSpecies/20151006_SOS_BartramsScrubHairstreak.pdf. Accessed on 

September 5, 2019.

U.S. Fish and Wildlife Service (USFWS). 2015c. Schaus’ Swallowtail Butterfly. 

https://www.fws.gov/refuge/Crocodile_Lake/wildlife_and_habitat/schaus_swallowtail/. Accessed on September 

5, 2019.

U.S. Fish and Wildlife Service (USFWS). 2016. Red-cockaded Woodpecker Recovery. 

https://www.fws.gov/rcwrecovery/rcw.html. Accessed on September 5, 2019.

U.S. Fish and Wildlife Service. 2019a. IPaC resource list. Miami-Dade County, Florida. https://ecos.fws.gov/ipac/. 

Accessed on August 14, 2019.
SECTION 5 – REFERENCES

5-6

U.S. Fish and Wildlife Service. 2019b. Critical Habitat Mapper. 

https://www.arcgis.com/home/item.html?id=2c2453ee613f47cdae9dbd0ed7939409. Accessed on August 14, 

2019.

U.S. Southern Command (SOUTHCOM). 2019. U.S. Southern Command. https://www.southcom.mil/.

Woolfenden, G. E. and J. W. Fitzpatrick. 1996. Florida Scrub-Jay (Aphelocoma coerulescens), version 2.0. In The 

Birds of North America (A. F. Poole and F. B. Gill, eds.). Cornell Lab of Ornithology, Ithaca, NY, 

USA. https://doi.org/10.2173/bna.228. Accessed on September 6, 2019.

World Health Organization. 2019. Electromagnetic fields and public health: radars and human health.

https://www.who.int/peh-emf/publications/facts/fs226/en/. Accessed on September 7, 2019.
SECTION 6

6-1

List of Preparers

Table 6-1. List of Preparers 

Construction of a Military Housing Development for USAG-Miami, Doral, Florida

Name Degree(s) Years of Work Experience

Ursula Rogers B.S. Biology 13

Laura Haught B.S. Biology 21

Betsy Jorgensen B.S. Biology 15

Rich Reaves Ph.D. Wetland and Wildlife Ecology 25

Caitlin Santinelli B.S. Earth and Atmospheric Sciences 8
SECTION 7

7-1

Distribution List

Florida State Clearing House

Miami-Dade Public Library – Doral Branch
SECTION 8

8-1

Persons Consulted

Mr. Matthew Fortunato

U.S. Army Garrison - Miami

Ms. Jenny Lechuga

U.S. Army Environmental Command
Appendix A

Government Correspondence
State Agency Correspondence, Tribal Correspondence,

and Cooperative Agreements will be included when they have been received.
Appendix B

Coastal Zone Consistency Determination
GES0917191342ATL B-1

APPENDIX B

Federal Agency Coastal Zone Management Act 

Consistency Determination

Introduction

This document provides the State of Florida with the Consistency Determination under Coastal Zone Management 

Act (CZMA) Section 307 and 15 Code of Federal Regulations (CFR) Part 930 subpart C developed by the United 

States Army Garrison-Miami (USAG-Miami). The information in this Consistency Determination is provided 

pursuant to 15 CFR Section 930.39 and Section 307 of the Coastal Zone Management Act, 16 United States Code 

(U.S.C.) § 1456, as amended, and its implementing regulations at 15 CFR Part 930. This federal consistency 

determination addresses the Proposed Action in the Environmental Assessment: of a Military Housing 

Development for U.S. Army Garrison-Miami, Doral, Florida for the building of a housing development on federal 

property acquired from the Federal Aviation Administration (FAA) and adjacent to U.S. Southern Command 

(SOUTHCOM).

Proposed Action

The Proposed Action is for USAG-Miami to acquire FAA land west of NW 92 Ave and south of NW 33rd Street 

across from the SOUTHCOM headquarters in Doral, Florida and construct a military housing development on the 

property. The property houses a large FAA radar tower and associated support buildings near its center and no 

housing would be constructed within the FAA established antenna standoff area to avoid interference with 

operation of the radar system; however, non-vertical assets such as stormwater retention infrastructure, roads, or 

parking may be located within this radius.

Proposed construction of the housing development would include construction of buildings with masonry block 

and stucco exterior wall and concrete tile roof. Family housing would have living areas, kitchens, bathrooms, 

bedrooms, storage, double-car garages, and private entrances. Unaccompanied housing units would have living 

and sleeping areas, baths, and storage. All housing would meet requirements for soundproofing, and all General 

Officers’ quarters would meet Sensitive Compartmented Information Facility requirements. Construction of 

supporting facilities would include the following site work: earthwork consisting of 3 feet of fill, utilities and 

connections, lighting, paving, parking, walks, curbs and gutters, storm drainage, information systems connectivity, 

the pedestrian walkway beneath NW 33rd Street, and landscaping and signage. Heating and air conditioning 

would be provided by self-contained systems, and residential smoke detectors would be provided.

The Army is considering two alternatives to implement the proposed action. The first is the MILCON Alternative 

that involves acquiring some or all of the approximately 160-acre FAA parcel to construct, operate, manage, and 

maintain service member housing on up to 75 acres of the property. Under this alternative, no building structures 

would be built on the central portion (52.4 acres) of the parcel as not to interfere with radar tower operations; 

however, non-vertical assets such as stormwater retention infrastructure, roads, or parking may be located within 

this radius. The second is the Enhanced Use Lease (EUL) Alternative, where USAG-Miami would obtain an EUL 

agreement with a private developer to construct and operate residential, retail, and parking spaces on up to 107.5 

acres of the approximately 160-acre FAA parcel. The same restriction on the 52.4 acre center as the MILCON 

Alternative would apply.

The consistency determination is based on the assumption that the military housing would be constructed and 

EUL-driven, mixed-use development could also occur.
B-2
APPENDIX B – FEDERAL AGENCY COASTAL ZONE MANAGEMENT ACT CONSISTENCY DETERMINATION

GES0917191342ATL B-3

Federal Consistency Review

The Proposed Action is consistent to the extent practicable with the enforceable provisions of the Florida Coastal 

Zone Management Program. Statutes addressed as part of the Florida Coastal Zone Management Program 

consistency review and considered in the analysis of the proposed action are discussed in the following table. 

Pursuant to 15 C.F.R. § 930.41, the Florida State Clearinghouse has 60 days from receipt of this document in which 

to concur with or object to this Consistency Determination, or to request an extension, in writing, under 15 C.F.R. 

§ 930.41(b). Florida’s concurrence will be presumed if USAG-Miami does not receive its response on the 60th day 

from receipt of this determination.

Table 1. Florida Coastal Management Program Consistency Review 

Statue Consistency Scope

Chapter 161

Beach and Shore 

Preservation

The proposed project would not 

adversely affect beach and shore 

management, specifically as it pertains 

to:

• The Coastal Construction Permit 

Program.

• The Coastal Construction Control Line 

(CCCL) Permit Program.

• The Coastal Zone Protection Program.

All land activities would occur inland on 

federal property.

Authorizes the Bureau of Beaches and Coastal 

Systems within Florida Department of 

Environmental Protection to regulate 

construction on or seaward of the states’ 

beaches.

Chapter 163, Part II 

Growth Policy; County and 

Municipal Planning; Land 

Development Regulation

The Proposed Action would not have a 

negative effect on county and municipal 

planning. The project is on federal land 

not subject to Miami-Dade County 

planning and land regulation. USAG- Miami would adhere to applicable 

policies.

Requires local governments to prepare, adopt, 

and implement comprehensive plans that 

encourage the most appropriate use of land and 

natural resources in a manner consistent with 

the public interest.

Chapter 186

State and Regional Planning

The Proposed Action would not have a 

negative effect on state plans for water 

use, land development, or 

transportation.

Details state-level planning requirements. 

Requires the development of special statewide 

plans governing water use, land development, 

and transportation.

Chapter 252

Emergency Management

The Proposed Action would not increase 

the state’s vulnerability to natural 

disasters. Emergency response and 

evacuation procedures would not be 

impacted by the Proposed Action.

Provides for planning and implementation of the 

state’s response to, efforts to recover from, and 

the mitigation of natural and manmade 

disasters.

Chapter 253

State Lands

All activities would occur on restricted 

federal property; therefore, there 

would be no impact to state or public 

lands.

Addresses the state’s administration of public 

lands and property of this state and provides 

direction regarding the acquisition, disposal, and 

management of all state lands.

Chapter 258

State Parks and Preserves

State parks, recreational areas, and 

aquatic preserves would not be affected 

by the Proposed Action.

Addresses administration and management of 

state parks and preserves (Chapter 258).

Chapter 259

Land Acquisition for 

Conservation or Recreation

Activities would be on federal land not 

subject to state acquisition at this time. 

Tourism and outdoor recreation would 

not be affected by the Proposed Action.

Authorizes acquisition of environmentally 

endangered lands and outdoor recreation lands 

(Chapter 259).

Chapter 260

Recreational Trails System

Opportunities for recreation on state 

lands would not be affected by the 

Proposed Action.

Authorizes acquisition of land to create a 

recreational trails system and to facilitate 

management of the system (Chapter 260).
APPENDIX B – FEDERAL AGENCY COASTAL ZONE MANAGEMENT ACT CONSISTENCY DETERMINATION

B-4 GES0917191342ATL

Table 1. Florida Coastal Management Program Consistency Review 

Statue Consistency Scope

Chapter 375

Multipurpose Outdoor 

Recreation; Land 

Acquisition, Management, 

and Conservation

Opportunities for recreation on state 

lands would not be affected by the 

Proposed Action.

Develops comprehensive multipurpose outdoor 

recreation plan to document recreational supply 

and demand, describe current recreational 

opportunities, estimate need for additional 

recreational opportunities, and propose means 

to meet the identified needs (Chapter 375).

Chapter 267

Historical Resources

A substantial portion of the FAA parcel 

has been previously disturbed from 

construction of the antenna and 

support buildings and for other 

infrastructure that has since been 

removed from the site. No 

archaeological or historical sites have 

been identified within the proposed 

project area. There would be no impacts 

to identified cultural resources under 

the Proposed Action.

Addresses management and preservation of the 

state’s archaeological and historical resources.

Chapter 288

Commercial Development 

and Capital Improvements

Military base closures or base reuse 

plans would not be affected by the 

Proposed Action. The EUL would 

promote and support commercial 

development.

Provides the framework for promoting and 

developing the general business, trade, and 

tourism components of the state economy.

Chapter 334

Transportation 

Administration

The Proposed Action would not have an 

impact on transportation other than 

short-term increased traffic volume and 

detours necessary for construction.

Addresses the state’s policy concerning 

transportation administration (Chapter 334).

Chapter 339

Transportation Finance and 

Planning

The Proposed Action would have no 

effect on the finance and planning 

needs of the state’s transportation 

system.

Addresses the finance and planning needs of the 

state’s transportation system (Chapter 339).

Chapter 370

Saltwater Fisheries 

The Proposed Action would not have an 

impact on saltwater fisheries.

Addresses management and protection of the 

state’s saltwater fisheries.

Chapter 372

Wildlife

The proposed project area is 

significantly disturbed and is dominated 

by exotic, invasive vegetation. Wildlife 

use would be limited but there could be 

limited displacement from foraging by 

species protected by the State of 

Florida. The Proposed Action would not 

have a negative impact on wildlife 

resources.

Addresses the management of the wildlife 

resources of the state.

Chapter 373

Water Resources

No impacts to water resources would 

occur. To reduce the potential for

impact to water resources, best 

management practices (BMPs) will be 

used to control erosion and stormwater 

runoff. Applicable permitting 

requirements will be satisfied in 

accordance with 62-25 Florida 

Administrative Code (FAC) and National 

Pollutant Discharge Elimination System 

(NPDES). An application for a NPDES 

stormwater permit would be filed prior 

to project initiation.

Addresses the state’s policy concerning water 

resources.

Chapter 376

Pollutant Discharge 

Prevention and Removal

The Proposed Action would not involve 

the discharge of pollutants.

Regulates transfer, storage, and transportation 

of pollutants, and cleanup of pollutant 

discharges.
APPENDIX B – FEDERAL AGENCY COASTAL ZONE MANAGEMENT ACT CONSISTENCY DETERMINATION

GES0917191342ATL B-5

Table 1. Florida Coastal Management Program Consistency Review 

Statue Consistency Scope

Chapter 377

Energy Resources

Energy resource production, including 

oil and gas, and the transportation of oil 

and gas, would not be affected by the 

Proposed Action.

Addresses regulation, planning, and 

development of oil and gas resources of the 

state.

Chapter 380

Land and Water 

Management

Under the Proposed Action, 

development of state lands with 

regional (i.e., more than one county) 

impacts would not occur. No changes to 

coastal infrastructure such as capacity 

increases of existing coastal 

infrastructure, or use of state funds for 

infrastructure planning, designing, or 

construction would occur. 

Establishes land and water management policies 

to guide and coordinate local decisions relating 

to growth and development.

Chapter 381

Public Health, General 

Provisions

The Proposed Action does not involve 

the construction of an onsite sewage or 

treatment system.

Establishes public policy concerning the state’s 

public health system.

Chapter 388

Mosquito Control

The Proposed Action would not affect 

mosquito control efforts. 

Addresses mosquito control effort in the state.

Chapter 403

Environmental Control

The Proposed Action would have no 

impact on groundwater, water quality, 

air quality, pollution control, solid waste 

management, or other environmental 

control efforts.

Establishes public policy concerning 

environmental control in the state.

Chapter 582

Soil and Water Conservation

The Proposed Action would include 

construction activities and soil 

disturbance. Appropriate BMPs would

be applied to prevent soil erosion and 

water quality degradation.

Establishes policies that require the 

conservation, development, and use of soil and 

water resources to preserve natural resources 

and control and prevent soil erosion. 
Appendix C

FONSI and Public Comments
1

Finding of No Significant Impact:

Construction of a Military Housing Development for U.S. Army 

Garrison-Miami, Doral, Florida

U.S. Army Garrison-Miami (USAG-Miami) has prepared an Environmental Assessment (EA) that evaluates the 

potential environmental and socioeconomic impacts associated with the construction of a military housing 

development in an adjacent property currently owned by the Federal Aviation Administration (FAA). A major 

tenant of USAG-Miami in Doral is the U.S. Southern Command (SOUTHCOM). USAG-Miami also supports 

SOUTHCOM’s subordinate commands, U.S. Marine Forces South and Special Operations Command South in 

Homestead, Florida, as well as various other organizations. 

There is no military housing on the USAG-Miami cantonment and no space within the cantonment to construct 

military housing. The purpose of the Proposed Action is to provide military housing for USAG-Miami’s housing 

requirement. This includes housing for 50 Key and Essential Family Units and 120 Unaccompanied Enlisted Units 

within 5 miles/15 minutes peak traffic commute from SOUTHCOM headquarters in Doral, Florida. This ensures 

essential personnel can walk to the installation and enables mission readiness. The remainder of the housing 

requirement (120 Family Units) should be within 20 miles/60 minutes peak traffic commute from SOUTHCOM 

headquarters. The need for the Proposed Action is to minimize mission interruption during emergency conditions 

and to improve security, increase affordability, and provide cohesion for families and staff. 

The attached EA, which is incorporated by reference, was prepared pursuant to 32 Code of Federal Regulations

(CFR) Part 651, the U.S. Council on Environmental Quality (CEQ) regulations (Title 40, U.S. Code, [USC] § 4321 et 

seq.) the CEQ National Environmental Policy Act (NEPA) Regulation (40 CFR 1500-1508); and applicable Army 

requirements, including the Army NEPA Regulation (32 CFR 651, Environmental Analysis of Army Actions) for 

implementing NEPA procedural requirements.

Description of the Proposed Action

The Proposed Action is for USAG-Miami to acquire FAA land south of NW 33rd Street across from the SOUTHCOM 

headquarters in Doral, Florida and construct a military housing development on the property. This action would 

construct enough units to address 90 percent of the Family Housing shortfall of 155 units and approximately 95 

percent of the Unaccompanied Housing shortfall of 140 units.

The property houses a large FAA radar tower and associated support buildings near its center. No housing 

development would be constructed within the FAA established antenna standoff area to avoid interference with 

operation of the radar system; however, non-vertical assets such as stormwater retention infrastructure, roads, or 

parking may be located within this radius. 

Alternative 1 – Military Construction Alternative

In the Military Construction (MILCON) Alternative, USAG-Miami would use congressionally approved appropriated 

funds to acquire some or all of the approximately 160-acre FAA parcel and pay for the construction, operation, 

management, and maintenance of service member housing on up to 75 acres of the property (refer to EA Figure 

2-1). The MILCON Alternative would consist of constructing and operating a housing development as described in 

the Proposed Action. Under this alternative, no building structures would be built on the central portion (52.4 

acres) of the parcel, so as not to interfere with radar tower operations; however, non-vertical assets such as 

stormwater retention infrastructure, roads, or parking may be located within this radius.
APPENDIX C—FINDING OF NO SIGNIFICANT IMPACT: 

DORAL, FLORIDA, CONSTRUCTION OF A MILITARY HOUSING DEVELOPMENT FOR U.S. ARMY GARRISON-MIAMI

2

Alternative 2 – Enhanced Use Lease Alternative

In the Enhanced Use Lease (EUL) Alternative, USAG-Miami would use an EUL agreement with a private developer 

to construct and operate a housing development on the approximately 160-acre FAA parcel (Figure 2-2). This 

alternative would consist of constructing and operating a housing development as described in the Proposed 

Action (refer to EA Section 2.1) on up to 75 acres of the northern portion of the FAA parcel. In addition, up to 32.5 

acres of the southern portion of the FAA parcel would be offered to a developer for a mixed-use development in 

exchange for funding the construction of the military housing. The total development footprint under this 

alternative would be 107.5 acres. The southern development would include up to 302,000 square feet of retail 

space below two levels of 167 apartments and would include up to 806 parking spaces. Under this alternative, no 

building structures would be built on the central portion (52.4 acres) of the parcel so as not to interfere with radar 

tower operations; however, non-vertical assets such as stormwater retention infrastructure, roads, or parking 

may be located within this radius.

Alternative 3 – No Action Alternative

Under the No Action Alternative, USAG-Miami would not acquire the FAA parcel directly adjacent to the 

SOUTHCOM headquarters in Doral, Florida, and would not construct a military housing development. Service 

members would continue to search for affordable housing in the local economy and be scattered across the city 

and county. This would continue to create an undue financial burden on many service members as they seek 

suitable quarters and would continue to adversely impact mission readiness for USAG-Miami and SOUTHCOM. 

Essential personnel would continue to be unable to quickly reach the SOUTHCOM headquarters facility to 

maintain operations during emergencies as a result of possible road closures and traffic. Higher-level personnel 

living offsite would not be provided with required additional security for personal protection.

Environmental Consequences

No significant environmental or socioeconomic consequences were identified in the EA as a result of the Proposed 

Action. 

Alternative 1 – Military Construction Alternative

Implementation of the MILCON Alternative would result in adverse impacts on land use, soils, groundwater, 

surface water, water quality, flood hazard area, air quality, noise, biological resources, socioeconomic resources, 

coastal zone management, safety and occupational health, hazardous materials, traffic and transportation, 

recreation, utilities, and visual resources. All of these impacts were determined to be less than significant. 

Applicable construction permits would be obtained, and health and safety procedures would be implemented

during construction. USAG-Miami would implement appropriate measures to further reduce less than significant 

unavoidable impacts of the proposed project. Project design measures would be used to minimize soil erosion, 

control fugitive dust emissions, manage hazardous materials, minimize construction-related traffic, and reduce 

the generation of wastes during construction and operations. Construction activities would occur during the 

daytime hours to reduce disturbance. 

The appearance of the FAA parcel would transition from undeveloped to developed. This change would be 

consistent with the land use designation resulting in negligible long-term adverse direct impacts to land use. 

There would be long-term moderate adverse direct impacts to soil from construction, but use of appropriate 

construction and post-construction best management practices (BMPs) would minimize soil erosion from 

stormwater runoff. Indirect adverse impacts to soils would be short-term and negligible during construction and 

long-term and minor during operation. There would be negligible long-term indirect adverse impacts to 

groundwater from construction and operation due to the size of the development (75 acres) compared to the size 

of the aquifer (4,000 square miles). Use of appropriate construction and post-construction BMPs and 

implementation of stormwater controls would result in no more than negligible adverse impacts to surface water 

resources and water quality during construction and operation. There would be a long-term minor adverse direct 

impact to flood hazard area from raising the ground surface. Indirect impacts to flood hazard area would be long-
APPENDIX C—FINDING OF NO SIGNIFICANT IMPACT: 

DORAL, FLORIDA, CONSTRUCTION OF A MILITARY HOUSING DEVELOPMENT FOR U.S. ARMY GARRISON-MIAMI

3

term, adverse but less than significant. There would be minor adverse direct impacts to air quality from 

construction (short-term) and operation (long-term). There would be moderate short-term adverse direct noise 

impacts during construction, but there would be no long-term impacts to noise-sensitive receptors from 

operational activities. Negligible long-term adverse indoor direct impacts from noise would be expected at any of 

the proposed residences within the 65 to 70 Day-Night Average Sound Level (DNL) noise contour for the Miami 

International Airport. There would be less than significant long-term adverse direct impacts from removal of 

vegetation during construction. There would be minor adverse direct impacts to wildlife from construction (shortterm) and operations (long-term). There would be negligible short-term adverse direct impacts to state special 

status animal species and limited to displacement of foraging animals. No impact to special-status plant species. 

No federally protected animal species are known to occur within the proposed project area and occurrence is 

unlikely due to the extent of encroachment by invasive exotic plant species and the high level of disturbance and 

surrounding development. USAG-Miami has determined there would be no effect to federally threatened, 

endangered, or candidate species or their habitats and no concurrence with USFWS is necessary. If any protected 

species are observed within the construction areas, construction would stop until the protected species 

voluntarily leaves the construction area. The overall impact to biological resources is expected to be less than 

significant. Minor to moderate short-term beneficial impacts to the local economy would result from the 

proposed construction. The MILCON Alternative would also have beneficial impacts on housing availability in the 

local area. There would be negligible to minor adverse direct impacts to fire, police, emergency, and medical 

services, and schools from an increase in permanent residents. The MILCON alternative is consistent with the 

enforceable provisions of the Florida Coastal Zone Management Program and there would be negligible long-term 

adverse direct impacts to coastal zone resources. There would be minor short-term adverse direct impacts to 

safety and occupational health from construction. No activities (construction or operations) would occur within 

the radio frequency radiation setback and there would be no adverse impacts to construction workers or 

residents from exposure to radio frequency radiation. There would be negligible short-term adverse direct and 

indirect impacts from use of small quantities of potentially hazardous materials (for example, gasoline, oils, 

coolant, lubricants, paints, and solvents) during construction. A stormwater pollution prevention plan and/or a 

project-specific construction safety plan would be followed to avoid significant risks or health hazards. There 

would be minor to moderate short-term adverse impacts to traffic and transportation during construction. 

Adverse impacts to traffic and transportation would be minor after the completion of construction. There would 

be negligible long-term indirect adverse impacts from the increased use of Doral Central Park by new residents of 

the housing development. There would be a minor increase in solid waste generation and a long-term change in 

demand on public utilities and services. Overall, there would be negligible to minor adverse direct impacts to

utilities from construction and operation of the Proposed Action. There would be moderate adverse direct 

impacts to visual resources, short-term and long-term, from construction and operation of the Proposed Action. 

The potential for cumulative negative impacts resulting from interaction of the MILCON Alternative with other 

past, present, and reasonably foreseeable projects is less than significant. Demolition, construction, and 

improvement projects could result in localized short-term cumulative impacts to soil, water resources, air quality, 

noise, biological resources, safety and occupational health, hazardous materials, and traffic and transportation if 

multiple proposed projects occur at the same time. Long-term minor cumulative impacts to traffic and 

transportation would occur as a result of the traffic from the new residents is added to the roadways and 

interacts with traffic associated with other reasonably foreseeable projects. There would be long-term minor 

cumulative adverse impacts to recreation if there is an increase in persons who move into the area or visit the 

area and use the new Doral Central Park facilities. There would be a long-term moderate cumulative adverse 

impact on utilities due the increased demand from the MILCON alternative combined with other proposed 

projects.

No significant impacts would result from the MILCON Alternative.

Alternative 2 – Enhanced Use Lease Alternative

Implementation of the EUL Alternative would include the consequences as described under the MILCON 

Alternative, some with a higher degree of impact than the MILCON Alternative (Alternative 1) due to the 32.5 
APPENDIX C—FINDING OF NO SIGNIFICANT IMPACT: 

DORAL, FLORIDA, CONSTRUCTION OF A MILITARY HOUSING DEVELOPMENT FOR U.S. ARMY GARRISON-MIAMI

4

acres of additional construction under the EUL Alternative associated with the mixed-use development. This 

would increase the duration and area of construction-related impacts. Even though there would be an increase in 

impacts for some resource areas due to the larger construction acreage, the impacts would be less than 

significant based on comparison to existing thresholds or regional baselines for the resources. Resources 

discussed below were determined to have a different impact level than the MILCON Alternative.

The EUL Alternative would have minor to moderate adverse direct effects to surface water due to the larger area 

of impervious surface (approximately 82 acres). Use of appropriate construction and post-construction BMPs and 

implementation of stormwater controls would reduce the surface water resource impacts which would still be 

less than significant. There would be negligible long-term impacts to noise-sensitive receptors. There would be 

minor to moderate long-term benefit on the local economy from new business opportunities and jobs associated 

with commercial-use property. There is potential for a long-term beneficial impact on regional roads as services 

are provided closer to where people live, which would reduce overall traffic. There would be minor indirect 

adverse impacts from the increased use of Doral Central Park by new residents of the housing development, 

mixed-use development, and potentially persons from outside the area patronizing the commercial development. 

The EUL Alternative would have greater impacts to utilities, as there would be new residents of the housing 

component and utility use by the commercial component that are not occurring at present, with minor long-term 

adverse direct impacts to energy sources and solid waste. While impacts would be greater than the MILCON 

Alternative, no significant impacts would result from the EUL Alternative. 

The potential for cumulative negative impacts resulting from interaction of the EUL Alternative with other past, 

present, and reasonably foreseeable projects is less than significant. Demolition, construction, and improvement 

projects could result in localized short-term cumulative impacts to water resources, air quality, noise, biological 

resources, safety and occupational health, hazardous materials, and traffic and transportation if multiple 

proposed projects occur at the same time. Long-term minor to moderate cumulative impacts to traffic and 

transportation would occur as a result of the traffic from the new residents and patrons of the commercial 

development is added to the roadways and interacts with traffic associated with other reasonably foreseeable 

projects. There would be long-term less than significant cumulative adverse impacts to recreation if there is an 

increase in persons who move into the area or visit the area and use the new Doral Central Park facilities. There 

would be a long-term moderate cumulative adverse impact on utilities due the increased demand from the 

MILCON alternative combined with other proposed projects.

No significant impacts would result from the EUL Alternative.

Alternative 3 – No Action Alternative

Under the No Action Alternative, conditions would remain as they are at USAG-Miami. Failure to accomplish the 

Proposed Action would result in a shortfall of housing for military personnel within a 5-mile commute for essential 

personnel and within a 20-mile commute for other personnel by 2023. Depending on where personnel can find 

housing, the lack of action could ultimately result in a minor to moderate long-term adverse direct impact to 

mission readiness. As service members are forced to seek housing farther away from the installation, mission 

readiness would be further adversely impacted due to essential personnel being unable to quickly reach the 

SOUTHCOM facility in the event of an emergency. In addition, the FAA may opt to dispose of the parcel adjacent 

to SOUTHCOM in the next few years; this would eliminate the possibility of revisiting the option of acquiring the 

FAA parcel in the future. Under the No Action Alternative, there is also the possibility that the FAA parcel would 

be developed in the future by another entity.

Public and Agency Review

A Notice of Availability of the Draft EA and the Finding of No Significant Impact (FONSI) will be published in the 

Miami Herald. The EA and FONSI will be made available to the public for a 30-day comment period. 
APPENDIX C—FINDING OF NO SIGNIFICANT IMPACT: 

DORAL, FLORIDA, CONSTRUCTION OF A MILITARY HOUSING DEVELOPMENT FOR U.S. ARMY GARRISON-MIAMI

5

Conclusion

Based on the analysis presented in the EA, I find that implementation of the Proposed Action would have no 

significant impact on the human or natural environment. Therefore, a FONSI is issued for the Proposed Action and

no Environmental Impact Statement is required.

U.S. Army Garrison-Miami

_______________________________________ __________________________________

Mrs. Greta M. Buccellato Date

Garrison Manager
1

Public Comments will be included when they have been received.
Appendix D

Air Quality Emission Estimates and 

Record of Non-Applicability
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-1

ALTERNATIVE 1

DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

1. General Information

- Action Location

Base: USAG-Miami

County(s): Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Action Title: USAG-Miami Housing Development

- Project Number/s (if applicable):

- Projected Action Start Date: 10 / 2023

- Action Purpose and Need:

USAG-Miami Housing Development

- Action Description:

USAG-Miami Housing Development

- Point of Contact

Name: Caitlin Santinelli

Title: Scientist

Organization: Jacobs

Email: caitlin.santinelli@jacobs.com

Phone Number: 678-530-4148

- Activity List:

Activity Type Activity Title

2. Construction / Demolition CDC

3. Construction / Demolition Community Center

4. Construction / Demolition Family Housing

5. Construction / Demolition Unaccompanied Housing

6. Construction / Demolition Access Control Point

7. Construction / Demolition Guardhouse/Bridge

8. Construction / Demolition Perimeter

9. Construction / Demolition Stormwater

10. Construction / Demolition Site Improvements

11. Construction / Demolition Utilities

12. Construction / Demolition Paving

13. Construction / Demolition Multipurpose Amenities

2. Construction / Demolition

2.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: CDC
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-2 GES0917191342ATL

- Activity Description:

- Activity Start Date

Start Month: 10

Start Month: 2023

- Activity End Date

Indefinite: False

End Month: 3

End Month: 2024

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.248289 PM 2.5 0.015971

SOx 0.001239 Pb 0.000000

NOx 0.393716 NH3 0.000478

CO 0.584761 CO2e 119.9

PM 10 0.016017

2.1 Building Construction Phase

2.1.1 Building Construction Phase Timeline Assumptions

- Phase Start Date

Start Month: 10

Start Quarter: 1

Start Year: 2023

- Phase Duration

Number of Month: 4

Number of Days: 0

2.1.2 Building Construction Phase Assumptions

- General Building Construction Information

Building Category: Commercial or Retail

Area of Building (ft2

): 15000

Height of Building (ft): 15

Number of Units: N/A

- Building Construction Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cranes Composite 1 4

Forklifts Composite 2 6

Tractors/Loaders/Backhoes Composite 1 8

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-3

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

- Vendor Trips

Average Vendor Round Trip Commute (mile): 40 (default)

- Vendor Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

2.1.3 Building Construction Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Cranes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0754 0.0013 0.5027 0.3786 0.0181 0.0181 0.0068 128.79

Forklifts Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0258 0.0006 0.1108 0.2145 0.0034 0.0034 0.0023 54.454

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0364 0.0007 0.2127 0.3593 0.0080 0.0080 0.0032 66.879

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

2.1.4 Building Construction Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-4 GES0917191342ATL

- Vehicle Exhaust Emissions per Phase

VMTVE = BA * BH * (0.32 / 1000) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.32 / 1000): Conversion Factor ft3 to trips (0.32 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Vender Trips Emissions per Phase

VMTVT = BA * BH * (0.05 / 1000) * HT

VMTVT: Vender Trips Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.05 / 1000): Conversion Factor ft3 to trips (0.05 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVT: Vender Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-5

2.2 Architectural Coatings Phase

2.2.1 Architectural Coatings Phase Timeline Assumptions

- Phase Start Date

Start Month: 2

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 0

Number of Days: 15

2.2.2 Architectural Coatings Phase Assumptions

- General Architectural Coatings Information

Building Category: Non-Residential

Total Square Footage (ft2

): 15000

Number of Units: N/A

- Architectural Coatings Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

2.2.3 Architectural Coatings Phase Emission Factor(s)

- Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

2.2.4 Architectural Coatings Phase Formula(s)

- Worker Trips Emissions per Phase

VMTWT = (1 * WT * PA) / 800

VMTWT: Worker Trips Vehicle Miles Travel (miles)

1: Conversion Factor man days to trips ( 1 trip / 1 man * day)

WT: Average Worker Round Trip Commute (mile)

PA: Paint Area (ft2

)

800: Conversion Factor square feet to man days ( 1 ft2 / 1 man * day)

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-6 GES0917191342ATL

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCAC = (AB * 2.0 * 0.0116) / 2000.0

VOCAC: Architectural Coating VOC Emissions (TONs)

BA: Area of Building (ft2

)

2.0: Conversion Factor total area to coated area (2.0 ft2 coated area / total area)

0.0116: Emission Factor (lb/ft2

)

2000: Conversion Factor pounds to tons

2.3 Paving Phase

2.3.1 Paving Phase Timeline Assumptions

- Phase Start Date

Start Month: 2

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 2

Number of Days: 0

2.3.2 Paving Phase Assumptions

- General Paving Information

Paving Area (ft2

): 18800

- Paving Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cement and Mortar Mixers Composite 4 6

Pavers Composite 1 7

Rollers Composite 1 7

Tractors/Loaders/Backhoes Composite 1 7

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-7

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

2.3.3 Paving Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.578 000.008 000.613 005.086 000.009 000.008 000.034 00391.932

LDGT 000.823 000.010 001.060 008.566 000.010 000.009 000.034 00522.586

HDGV 001.597 000.016 002.785 026.982 000.023 000.020 000.046 00814.010

LDDV 000.216 000.004 000.307 004.001 000.006 000.006 000.008 00402.372

LDDT 000.537 000.006 000.822 008.176 000.008 000.008 000.008 00626.077

HDDV 000.762 000.015 007.639 002.810 000.395 000.363 000.028 01633.017

MC 003.190 000.008 000.648 014.785 000.027 000.024 000.048 00392.026

2.3.4 Paving Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = PA * 0.25 * (1 / 27) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

PA: Paving Area (ft2

)

0.25: Thickness of Paving Area (ft)

(1 / 27): Conversion Factor cubic feet to cubic yards ( 1 yd3 / 27 ft3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-8 GES0917191342ATL

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCP = (2.62 * PA) / 43560

VOCP: Paving VOC Emissions (TONs)

2.62: Emission Factor (lb/acre)

PA: Paving Area (ft2

)

43560: Conversion Factor square feet to acre (43560 ft2 / acre)2 / acre)

3. Construction / Demolition

3.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Community Center

- Activity Description:

- Activity Start Date

Start Month: 10

Start Month: 2023

- Activity End Date

Indefinite: False

End Month: 3

End Month: 2024

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.248914 PM 2.5 0.016261

SOx 0.001264 Pb 0.000000

NOx 0.401192 NH3 0.000528

CO 0.587721 CO2e 122.7

PM 10 0.016332

3.1 Building Construction Phase
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-9

3.1.1 Building Construction Phase Timeline Assumptions

- Phase Start Date

Start Month: 10

Start Quarter: 1

Start Year: 2023

- Phase Duration

Number of Month: 4

Number of Days: 0

3.1.2 Building Construction Phase Assumptions

- General Building Construction Information

Building Category: Commercial or Retail

Area of Building (ft2

): 15000

Height of Building (ft): 30

Number of Units: N/A

- Building Construction Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cranes Composite 1 4

Forklifts Composite 2 6

Tractors/Loaders/Backhoes Composite 1 8

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

- Vendor Trips

Average Vendor Round Trip Commute (mile): 40 (default)

- Vendor Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

3.1.3 Building Construction Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-10 GES0917191342ATL

Cranes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0754 0.0013 0.5027 0.3786 0.0181 0.0181 0.0068 128.79

Forklifts Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0258 0.0006 0.1108 0.2145 0.0034 0.0034 0.0023 54.454

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0364 0.0007 0.2127 0.3593 0.0080 0.0080 0.0032 66.879

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

3.1.4 Building Construction Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = BA * BH * (0.32 / 1000) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.32 / 1000): Conversion Factor ft3 to trips (0.32 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-11

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Vender Trips Emissions per Phase

VMTVT = BA * BH * (0.05 / 1000) * HT

VMTVT: Vender Trips Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.05 / 1000): Conversion Factor ft3 to trips (0.05 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVT: Vender Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

3.2 Architectural Coatings Phase

3.2.1 Architectural Coatings Phase Timeline Assumptions

- Phase Start Date

Start Month: 2

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 0

Number of Days: 15

3.2.2 Architectural Coatings Phase Assumptions

- General Architectural Coatings Information

Building Category: Non-Residential

Total Square Footage (ft2

): 15000

Number of Units: N/A

- Architectural Coatings Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Worker Trips
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-12 GES0917191342ATL

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

3.2.3 Architectural Coatings Phase Emission Factor(s)

- Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

3.2.4 Architectural Coatings Phase Formula(s)

- Worker Trips Emissions per Phase

VMTWT = (1 * WT * PA) / 800

VMTWT: Worker Trips Vehicle Miles Travel (miles)

1: Conversion Factor man days to trips ( 1 trip / 1 man * day)

WT: Average Worker Round Trip Commute (mile)

PA: Paint Area (ft2

)

800: Conversion Factor square feet to man days ( 1 ft2 / 1 man * day)

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCAC = (AB * 2.0 * 0.0116) / 2000.0

VOCAC: Architectural Coating VOC Emissions (TONs)

BA: Area of Building (ft2

)

2.0: Conversion Factor total area to coated area (2.0 ft2 coated area / total area)

0.0116: Emission Factor (lb/ft2

)

2000: Conversion Factor pounds to tons

3.3 Paving Phase

3.3.1 Paving Phase Timeline Assumptions

- Phase Start Date

Start Month: 2

Start Quarter: 1

Start Year: 2024
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-13

- Phase Duration

Number of Month: 2

Number of Days: 0

3.3.2 Paving Phase Assumptions

- General Paving Information

Paving Area (ft2

): 14400

- Paving Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cement and Mortar Mixers Composite 4 6

Pavers Composite 1 7

Rollers Composite 1 7

Tractors/Loaders/Backhoes Composite 1 7

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

3.3.3 Paving Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.578 000.008 000.613 005.086 000.009 000.008 000.034 00391.932

LDGT 000.823 000.010 001.060 008.566 000.010 000.009 000.034 00522.586

HDGV 001.597 000.016 002.785 026.982 000.023 000.020 000.046 00814.010

LDDV 000.216 000.004 000.307 004.001 000.006 000.006 000.008 00402.372

LDDT 000.537 000.006 000.822 008.176 000.008 000.008 000.008 00626.077

HDDV 000.762 000.015 007.639 002.810 000.395 000.363 000.028 01633.017

MC 003.190 000.008 000.648 014.785 000.027 000.024 000.048 00392.026

3.3.4 Paving Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-14 GES0917191342ATL

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = PA * 0.25 * (1 / 27) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

PA: Paving Area (ft2

)

0.25: Thickness of Paving Area (ft)

(1 / 27): Conversion Factor cubic feet to cubic yards ( 1 yd3 / 27 ft3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCP = (2.62 * PA) / 43560

VOCP: Paving VOC Emissions (TONs)

2.62: Emission Factor (lb/acre)

PA: Paving Area (ft2

)

43560: Conversion Factor square feet to acre (43560 ft2 / acre)2 / acre)

4. Construction / Demolition
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-15

4.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Family Housing

- Activity Description:

- Activity Start Date

Start Month: 4

Start Month: 2024

- Activity End Date

Indefinite: False

End Month: 3

End Month: 2025

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 2.331104 PM 2.5 0.055448

SOx 0.004729 Pb 0.000000

NOx 1.526412 NH3 0.001392

CO 2.170465 CO2e 454.3

PM 10 0.055528

4.1 Building Construction Phase

4.1.1 Building Construction Phase Timeline Assumptions

- Phase Start Date

Start Month: 4

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 12

Number of Days: 0

4.1.2 Building Construction Phase Assumptions

- General Building Construction Information

Building Category: Multi-Family

Area of Building (ft2

): 314706

Height of Building (ft): N/A

Number of Units: 155

- Building Construction Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-16 GES0917191342ATL

Equipment Name Number Of 

Equipment

Hours Per Day

Cranes Composite 1 7

Forklifts Composite 2 7

Generator Sets Composite 1 8

Tractors/Loaders/Backhoes Composite 1 8

Welders Composite 3 8

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

- Vendor Trips

Average Vendor Round Trip Commute (mile): 40 (default)

- Vendor Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

4.1.3 Building Construction Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Cranes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0715 0.0013 0.4600 0.3758 0.0161 0.0161 0.0064 128.78

Forklifts Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0246 0.0006 0.0973 0.2146 0.0029 0.0029 0.0022 54.451

Generator Sets Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0303 0.0006 0.2464 0.2674 0.0091 0.0091 0.0027 61.061

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0348 0.0007 0.1980 0.3589 0.0068 0.0068 0.0031 66.875

Welders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0227 0.0003 0.1427 0.1752 0.0059 0.0059 0.0020 25.653

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-17

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

4.1.4 Building Construction Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = NU * 0.36 * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

NU: Number of Units

0.36: Conversion Factor units to trips

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Vender Trips Emissions per Phase

VMTVT = NU * 0.11 * HT

VMTVT: Vender Tips Vehicle Miles Travel (miles)

NU: Number of Units

0.11: Conversion Factor units to trips
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-18 GES0917191342ATL

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVT: Vender Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

4.2 Architectural Coatings Phase

4.2.1 Architectural Coatings Phase Timeline Assumptions

- Phase Start Date

Start Month: 2

Start Quarter: 1

Start Year: 2025

- Phase Duration

Number of Month: 2

Number of Days: 0

4.2.2 Architectural Coatings Phase Assumptions

- General Architectural Coatings Information

Building Category: Multi-Family

Total Square Footage (ft2

): N/A

Number of Units: 155

- Architectural Coatings Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

4.2.3 Architectural Coatings Phase Emission Factor(s)

- Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

4.2.4 Architectural Coatings Phase Formula(s)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-19

- Worker Trips Emissions per Phase

VMTWT = (1 * WT * PA) / 800

VMTWT: Worker Trips Vehicle Miles Travel (miles)

1: Conversion Factor man days to trips ( 1 trip / 1 man * day)

WT: Average Worker Round Trip Commute (mile)

PA: Paint Area (ft2

)

800: Conversion Factor square feet to man days ( 1 ft2 / 1 man * day)

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCAC = (NU * 850 * 2.7 * 0.0116) / 2000.0

VOCAC: Architectural Coating VOC Emissions (TONs)

NU: Number of Units

850: Conversion Factor units to square feet (850 ft2 / unit)

2.7: Conversion Factor total area to coated area (2.7 ft2 coated area / total area)

0.0116: Emission Factor (lb/ft2

)

2000: Conversion Factor pounds to tons

5. Construction / Demolition

5.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Unaccompanied Housing

- Activity Description:

- Activity Start Date

Start Month: 4

Start Month: 2024

- Activity End Date

Indefinite: False

End Month: 11

End Month: 2024

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.900095 PM 2.5 0.035012
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-20 GES0917191342ATL

SOx 0.002931 Pb 0.000000

NOx 0.959431 NH3 0.000918

CO 1.376608 CO2e 281.7

PM 10 0.035060

5.1 Building Construction Phase

5.1.1 Building Construction Phase Timeline Assumptions

- Phase Start Date

Start Month: 4

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 8

Number of Days: 0

5.1.2 Building Construction Phase Assumptions

- General Building Construction Information

Building Category: Multi-Family

Area of Building (ft2

): 93800

Height of Building (ft): N/A

Number of Units: 70

- Building Construction Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cranes Composite 1 6

Forklifts Composite 2 6

Generator Sets Composite 1 8

Tractors/Loaders/Backhoes Composite 1 8

Welders Composite 3 8

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

- Vendor Trips

Average Vendor Round Trip Commute (mile): 40 (default)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-21

- Vendor Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

5.1.3 Building Construction Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Cranes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0715 0.0013 0.4600 0.3758 0.0161 0.0161 0.0064 128.78

Forklifts Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0246 0.0006 0.0973 0.2146 0.0029 0.0029 0.0022 54.451

Generator Sets Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0303 0.0006 0.2464 0.2674 0.0091 0.0091 0.0027 61.061

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0348 0.0007 0.1980 0.3589 0.0068 0.0068 0.0031 66.875

Welders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0227 0.0003 0.1427 0.1752 0.0059 0.0059 0.0020 25.653

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

5.1.4 Building Construction Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = NU * 0.36 * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

NU: Number of Units

0.36: Conversion Factor units to trips

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-22 GES0917191342ATL

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Vender Trips Emissions per Phase

VMTVT = NU * 0.11 * HT

VMTVT: Vender Tips Vehicle Miles Travel (miles)

NU: Number of Units

0.11: Conversion Factor units to trips

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVT: Vender Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

5.2 Architectural Coatings Phase

5.2.1 Architectural Coatings Phase Timeline Assumptions

- Phase Start Date

Start Month: 11

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 0

Number of Days: 23
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-23

5.2.2 Architectural Coatings Phase Assumptions

- General Architectural Coatings Information

Building Category: Multi-Family

Total Square Footage (ft2

): N/A

Number of Units: 55

- Architectural Coatings Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

5.2.3 Architectural Coatings Phase Emission Factor(s)

- Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

5.2.4 Architectural Coatings Phase Formula(s)

- Worker Trips Emissions per Phase

VMTWT = (1 * WT * PA) / 800

VMTWT: Worker Trips Vehicle Miles Travel (miles)

1: Conversion Factor man days to trips ( 1 trip / 1 man * day)

WT: Average Worker Round Trip Commute (mile)

PA: Paint Area (ft2

)

800: Conversion Factor square feet to man days ( 1 ft2 / 1 man * day)

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCAC = (NU * 850 * 2.7 * 0.0116) / 2000.0

VOCAC: Architectural Coating VOC Emissions (TONs)

NU: Number of Units
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-24 GES0917191342ATL

850: Conversion Factor units to square feet (850 ft2 / unit)

2.7: Conversion Factor total area to coated area (2.7 ft2 coated area / total area)

0.0116: Emission Factor (lb/ft2

)

2000: Conversion Factor pounds to tons

6. Construction / Demolition

6.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Access Control Point

- Activity Description:

- Activity Start Date

Start Month: 12

Start Month: 2024

- Activity End Date

Indefinite: False

End Month: 1

End Month: 2025

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.049242 PM 2.5 0.003461

SOx 0.000411 Pb 0.000000

NOx 0.103610 NH3 0.000131

CO 0.171441 CO2e 39.8

PM 10 0.003475

6.1 Building Construction Phase

6.1.1 Building Construction Phase Timeline Assumptions

- Phase Start Date

Start Month: 12

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 2

Number of Days: 0

6.1.2 Building Construction Phase Assumptions

- General Building Construction Information

Building Category: Office or Industrial

Area of Building (ft2

): 2480

Height of Building (ft): 15
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-25

Number of Units: N/A

- Building Construction Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cranes Composite 1 4

Forklifts Composite 2 6

Tractors/Loaders/Backhoes Composite 1 8

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

- Vendor Trips

Average Vendor Round Trip Commute (mile): 40 (default)

- Vendor Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

6.1.3 Building Construction Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Cranes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0715 0.0013 0.4600 0.3758 0.0161 0.0161 0.0064 128.78

Forklifts Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0246 0.0006 0.0973 0.2146 0.0029 0.0029 0.0022 54.451

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0348 0.0007 0.1980 0.3589 0.0068 0.0068 0.0031 66.875

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-26 GES0917191342ATL

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

6.1.4 Building Construction Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = BA * BH * (0.42 / 1000) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.42 / 1000): Conversion Factor ft3 to trips (0.42 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Vender Trips Emissions per Phase

VMTVT = BA * BH * (0.38 / 1000) * HT

VMTVT: Vender Trips Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-27

(0.38 / 1000): Conversion Factor ft3 to trips (0.38 trip / 1000 ft3)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVT: Vender Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

6.2 Architectural Coatings Phase

6.2.1 Architectural Coatings Phase Timeline Assumptions

- Phase Start Date

Start Month: 1

Start Quarter: 3

Start Year: 2025

- Phase Duration

Number of Month: 0

Number of Days: 10

6.2.2 Architectural Coatings Phase Assumptions

- General Architectural Coatings Information

Building Category:

Total Square Footage (ft2

): 2480

Number of Units: N/A

- Architectural Coatings Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

6.2.3 Architectural Coatings Phase Emission Factor(s)

- Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-28 GES0917191342ATL

6.2.4 Architectural Coatings Phase Formula(s)

- Worker Trips Emissions per Phase

VMTWT = (1 * WT * PA) / 800

VMTWT: Worker Trips Vehicle Miles Travel (miles)

1: Conversion Factor man days to trips ( 1 trip / 1 man * day)

WT: Average Worker Round Trip Commute (mile)

PA: Paint Area (ft2

)

800: Conversion Factor square feet to man days ( 1 ft2 / 1 man * day)

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCAC = (AB * 2.0 * 0.0116) / 2000.0

VOCAC: Architectural Coating VOC Emissions (TONs)

BA: Area of Building (ft2

)

2.0: Conversion Factor total area to coated area (2.0 ft2 coated area / total area)

0.0116: Emission Factor (lb/ft2

)

2000: Conversion Factor pounds to tons

7. Construction / Demolition

7.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Guardhouse/Bridge

- Activity Description:

- Activity Start Date

Start Month: 2

Start Month: 2025

- Activity End Date

Indefinite: False

End Month: 5

End Month: 2025

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.121548 PM 2.5 0.026202
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-29

SOx 0.002041 Pb 0.000000

NOx 0.674525 NH3 0.000772

CO 1.005596 CO2e 197.4

PM 10 0.026280

7.1 Building Construction Phase

7.1.1 Building Construction Phase Timeline Assumptions

- Phase Start Date

Start Month: 2

Start Quarter: 1

Start Year: 2025

- Phase Duration

Number of Month: 4

Number of Days: 0

7.1.2 Building Construction Phase Assumptions

- General Building Construction Information

Building Category: Commercial or Retail

Area of Building (ft2

): 26565

Height of Building (ft): 15

Number of Units: N/A

- Building Construction Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cranes Composite 1 6

Forklifts Composite 2 6

Generator Sets Composite 1 8

Tractors/Loaders/Backhoes Composite 1 8

Welders Composite 3 8

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

- Vendor Trips

Average Vendor Round Trip Commute (mile): 40 (default)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-30 GES0917191342ATL

- Vendor Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

7.1.3 Building Construction Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Cranes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0680 0.0013 0.4222 0.3737 0.0143 0.0143 0.0061 128.77

Forklifts Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0236 0.0006 0.0859 0.2147 0.0025 0.0025 0.0021 54.449

Generator Sets Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0287 0.0006 0.2329 0.2666 0.0080 0.0080 0.0025 61.057

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0335 0.0007 0.1857 0.3586 0.0058 0.0058 0.0030 66.872

Welders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0214 0.0003 0.1373 0.1745 0.0051 0.0051 0.0019 25.650

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

7.1.4 Building Construction Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = BA * BH * (0.32 / 1000) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.32 / 1000): Conversion Factor ft3 to trips (0.32 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-31

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Vender Trips Emissions per Phase

VMTVT = BA * BH * (0.05 / 1000) * HT

VMTVT: Vender Trips Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.05 / 1000): Conversion Factor ft3 to trips (0.05 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVT: Vender Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

7.2 Paving Phase

7.2.1 Paving Phase Timeline Assumptions

- Phase Start Date

Start Month: 4

Start Quarter: 1

Start Year: 2025

- Phase Duration

Number of Month: 2
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-32 GES0917191342ATL

Number of Days: 0

7.2.2 Paving Phase Assumptions

- General Paving Information

Paving Area (ft2

): 26500

- Paving Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cement and Mortar Mixers Composite 4 6

Pavers Composite 1 7

Paving Equipment Composite 1 8

Rollers Composite 1 7

Tractors/Loaders/Backhoes Composite 1 7

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

7.2.3 Paving Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.578 000.008 000.613 005.086 000.009 000.008 000.034 00391.932

LDGT 000.823 000.010 001.060 008.566 000.010 000.009 000.034 00522.586

HDGV 001.597 000.016 002.785 026.982 000.023 000.020 000.046 00814.010

LDDV 000.216 000.004 000.307 004.001 000.006 000.006 000.008 00402.372

LDDT 000.537 000.006 000.822 008.176 000.008 000.008 000.008 00626.077

HDDV 000.762 000.015 007.639 002.810 000.395 000.363 000.028 01633.017

MC 003.190 000.008 000.648 014.785 000.027 000.024 000.048 00392.026

7.2.4 Paving Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-33

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = PA * 0.25 * (1 / 27) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

PA: Paving Area (ft2

)

0.25: Thickness of Paving Area (ft)

(1 / 27): Conversion Factor cubic feet to cubic yards ( 1 yd3 / 27 ft3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCP = (2.62 * PA) / 43560

VOCP: Paving VOC Emissions (TONs)

2.62: Emission Factor (lb/acre)

PA: Paving Area (ft2

)

43560: Conversion Factor square feet to acre (43560 ft2 / acre)2 / acre)

8. Construction / Demolition

8.1 General Information & Timeline Assumptions
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-34 GES0917191342ATL

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Perimeter

- Activity Description:

- Activity Start Date

Start Month: 4

Start Month: 2025

- Activity End Date

Indefinite: False

End Month: 5

End Month: 2025

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.019853 PM 2.5 0.003133

SOx 0.000431 Pb 0.000000

NOx 0.090323 NH3 0.000056

CO 0.167589 CO2e 40.7

PM 10 0.179453

8.1 Trenching/Excavating Phase

8.1.1 Trenching / Excavating Phase Timeline Assumptions

- Phase Start Date

Start Month: 4

Start Quarter: 1

Start Year: 2025

- Phase Duration

Number of Month: 1

Number of Days: 0

8.1.2 Trenching / Excavating Phase Assumptions

- General Trenching/Excavating Information

Area of Site to be Trenched/Excavated (ft2

): 17724

Amount of Material to be Hauled On-Site (yd3

): 0

Amount of Material to be Hauled Off-Site (yd3

): 0

- Trenching Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Excavators Composite 2 8
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-35

Other General Industrial Equipment Composite 1 8

Tractors/Loaders/Backhoes Composite 1 8

- Vehicle Exhaust

Average Hauling Truck Capacity (yd3

): 20 (default)

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

8.1.3 Trenching / Excavating Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.578 000.008 000.613 005.086 000.009 000.008 000.034 00391.932

LDGT 000.823 000.010 001.060 008.566 000.010 000.009 000.034 00522.586

HDGV 001.597 000.016 002.785 026.982 000.023 000.020 000.046 00814.010

LDDV 000.216 000.004 000.307 004.001 000.006 000.006 000.008 00402.372

LDDT 000.537 000.006 000.822 008.176 000.008 000.008 000.008 00626.077

HDDV 000.762 000.015 007.639 002.810 000.395 000.363 000.028 01633.017

MC 003.190 000.008 000.648 014.785 000.027 000.024 000.048 00392.026

8.1.4 Trenching / Excavating Phase Formula(s)

- Fugitive Dust Emissions per Phase

PM10FD = (20 * ACRE * WD) / 2000

PM10FD: Fugitive Dust PM 10 Emissions (TONs)

20: Conversion Factor Acre Day to pounds (20 lb / 1 Acre Day)

ACRE: Total acres (acres)

WD: Number of Total Work Days (days)

2000: Conversion Factor pounds to tons

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = (HAOnSite + HAOffSite) * (1 / HC) * HT
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-36 GES0917191342ATL

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

HAOnSite: Amount of Material to be Hauled On-Site (yd3

)

HAOffSite: Amount of Material to be Hauled Off-Site (yd3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

9. Construction / Demolition

9.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Stormwater

- Activity Description:

- Activity Start Date

Start Month: 6

Start Month: 2025

- Activity End Date

Indefinite: False
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-37

End Month: 8

End Month: 2025

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.059558 PM 2.5 0.009399

SOx 0.001292 Pb 0.000000

NOx 0.270970 NH3 0.000168

CO 0.502768 CO2e 122.1

PM 10 2.512503

9.1 Trenching/Excavating Phase

9.1.1 Trenching / Excavating Phase Timeline Assumptions

- Phase Start Date

Start Month: 6

Start Quarter: 1

Start Year: 2025

- Phase Duration

Number of Month: 3

Number of Days: 0

9.1.2 Trenching / Excavating Phase Assumptions

- General Trenching/Excavating Information

Area of Site to be Trenched/Excavated (ft2

): 83873

Amount of Material to be Hauled On-Site (yd3

): 0

Amount of Material to be Hauled Off-Site (yd3

): 0

- Trenching Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Excavators Composite 2 8

Other General Industrial Equipment Composite 1 8

Tractors/Loaders/Backhoes Composite 1 8

- Vehicle Exhaust

Average Hauling Truck Capacity (yd3

): 20 (default)

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-38 GES0917191342ATL

POVs 50.00 50.00 0 0 0 0 0

9.1.3 Trenching / Excavating Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.578 000.008 000.613 005.086 000.009 000.008 000.034 00391.932

LDGT 000.823 000.010 001.060 008.566 000.010 000.009 000.034 00522.586

HDGV 001.597 000.016 002.785 026.982 000.023 000.020 000.046 00814.010

LDDV 000.216 000.004 000.307 004.001 000.006 000.006 000.008 00402.372

LDDT 000.537 000.006 000.822 008.176 000.008 000.008 000.008 00626.077

HDDV 000.762 000.015 007.639 002.810 000.395 000.363 000.028 01633.017

MC 003.190 000.008 000.648 014.785 000.027 000.024 000.048 00392.026

9.1.4 Trenching / Excavating Phase Formula(s)

- Fugitive Dust Emissions per Phase

PM10FD = (20 * ACRE * WD) / 2000

PM10FD: Fugitive Dust PM 10 Emissions (TONs)

20: Conversion Factor Acre Day to pounds (20 lb / 1 Acre Day)

ACRE: Total acres (acres)

WD: Number of Total Work Days (days)

2000: Conversion Factor pounds to tons

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = (HAOnSite + HAOffSite) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

HAOnSite: Amount of Material to be Hauled On-Site (yd3

)

HAOffSite: Amount of Material to be Hauled Off-Site (yd3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-39

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

10. Construction / Demolition

10.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Site Improvements

- Activity Description:

- Activity Start Date

Start Month: 6

Start Month: 2025

- Activity End Date

Indefinite: False

End Month: 3

End Month: 2026

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 2.756749 PM 2.5 0.973991

SOx 0.084153 Pb 0.000000

NOx 25.123406 NH3 0.152120

CO 11.845070 CO2e 9272.7

PM 10 98.549666

10.1 Site Grading Phase

10.1.1 Site Grading Phase Timeline Assumptions

- Phase Start Date
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-40 GES0917191342ATL

Start Month: 10

Start Quarter: 1

Start Year: 2025

- Phase Duration

Number of Month: 6

Number of Days: 0

10.1.2 Site Grading Phase Assumptions

- General Site Grading Information

Area of Site to be Graded (ft2

): 1633500

Amount of Material to be Hauled On-Site (yd3

): 4900500

Amount of Material to be Hauled Off-Site (yd3

): 0

- Site Grading Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Excavators Composite 1 8

Graders Composite 1 8

Other Construction Equipment Composite 1 8

Rubber Tired Dozers Composite 1 8

Scrapers Composite 3 8

Tractors/Loaders/Backhoes Composite 3 8

- Vehicle Exhaust

Average Hauling Truck Capacity (yd3

): 20 (default)

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

10.1.3 Site Grading Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Excavators Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0559 0.0013 0.2269 0.5086 0.0086 0.0086 0.0050 119.70

Graders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0676 0.0014 0.3314 0.5695 0.0147 0.0147 0.0061 132.89

Other Construction Equipment Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-41

Emission Factors 0.0442 0.0012 0.2021 0.3473 0.0068 0.0068 0.0039 122.60

Rubber Tired Dozers Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.1671 0.0024 1.0824 0.6620 0.0418 0.0418 0.0150 239.45

Scrapers Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.1495 0.0026 0.8387 0.7186 0.0334 0.0334 0.0134 262.81

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0335 0.0007 0.1857 0.3586 0.0058 0.0058 0.0030 66.872

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

10.1.4 Site Grading Phase Formula(s)

- Fugitive Dust Emissions per Phase

PM10FD = (20 * ACRE * WD) / 2000

PM10FD: Fugitive Dust PM 10 Emissions (TONs)

20: Conversion Factor Acre Day to pounds (20 lb / 1 Acre Day)

ACRE: Total acres (acres)

WD: Number of Total Work Days (days)

2000: Conversion Factor pounds to tons

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = (HAOnSite + HAOffSite) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

HAOnSite: Amount of Material to be Hauled On-Site (yd3

)

HAOffSite: Amount of Material to be Hauled Off-Site (yd3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-42 GES0917191342ATL

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

11. Construction / Demolition

11.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Utilities

- Activity Description:

- Activity Start Date

Start Month: 8

Start Month: 2025

- Activity End Date

Indefinite: False

End Month: 10

End Month: 2025

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.059558 PM 2.5 0.009399

SOx 0.001292 Pb 0.000000

NOx 0.270970 NH3 0.000168

CO 0.502768 CO2e 122.1

PM 10 8.303890
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-43

11.1 Trenching/Excavating Phase

11.1.1 Trenching / Excavating Phase Timeline Assumptions

- Phase Start Date

Start Month: 8

Start Quarter: 1

Start Year: 2025

- Phase Duration

Number of Month: 3

Number of Days: 0

11.1.2 Trenching / Excavating Phase Assumptions

- General Trenching/Excavating Information

Area of Site to be Trenched/Excavated (ft2

): 277929

Amount of Material to be Hauled On-Site (yd3

): 0

Amount of Material to be Hauled Off-Site (yd3

): 0

- Trenching Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Excavators Composite 2 8

Other General Industrial Equipment Composite 1 8

Tractors/Loaders/Backhoes Composite 1 8

- Vehicle Exhaust

Average Hauling Truck Capacity (yd3

): 20 (default)

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

11.1.3 Trenching / Excavating Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.578 000.008 000.613 005.086 000.009 000.008 000.034 00391.932

LDGT 000.823 000.010 001.060 008.566 000.010 000.009 000.034 00522.586

HDGV 001.597 000.016 002.785 026.982 000.023 000.020 000.046 00814.010
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-44 GES0917191342ATL

LDDV 000.216 000.004 000.307 004.001 000.006 000.006 000.008 00402.372

LDDT 000.537 000.006 000.822 008.176 000.008 000.008 000.008 00626.077

HDDV 000.762 000.015 007.639 002.810 000.395 000.363 000.028 01633.017

MC 003.190 000.008 000.648 014.785 000.027 000.024 000.048 00392.026

11.1.4 Trenching / Excavating Phase Formula(s)

- Fugitive Dust Emissions per Phase

PM10FD = (20 * ACRE * WD) / 2000

PM10FD: Fugitive Dust PM 10 Emissions (TONs)

20: Conversion Factor Acre Day to pounds (20 lb / 1 Acre Day)

ACRE: Total acres (acres)

WD: Number of Total Work Days (days)

2000: Conversion Factor pounds to tons

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = (HAOnSite + HAOffSite) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

HAOnSite: Amount of Material to be Hauled On-Site (yd3

)

HAOffSite: Amount of Material to be Hauled Off-Site (yd3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-45

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

12. Construction / Demolition

12.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Paving

- Activity Description:

- Activity Start Date

Start Month: 11

Start Month: 2025

- Activity End Date

Indefinite: False

End Month: 5

End Month: 2026

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.302473 PM 2.5 0.062777

SOx 0.004233 Pb 0.000000

NOx 1.421290 NH3 0.001038

CO 1.685878 CO2e 423.7

PM 10 33.253687

12.1 Site Grading Phase

12.1.1 Site Grading Phase Timeline Assumptions

- Phase Start Date

Start Month: 11

Start Quarter: 1

Start Year: 2025

- Phase Duration

Number of Month: 2

Number of Days: 0

12.1.2 Site Grading Phase Assumptions

- General Site Grading Information

Area of Site to be Graded (ft2

): 1668213
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-46 GES0917191342ATL

Amount of Material to be Hauled On-Site (yd3): 0

Amount of Material to be Hauled Off-Site (yd3

): 0

- Site Grading Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Excavators Composite 1 8

Graders Composite 1 8

Other Construction Equipment Composite 1 8

Rubber Tired Dozers Composite 1 8

Scrapers Composite 3 8

Tractors/Loaders/Backhoes Composite 3 8

- Vehicle Exhaust

Average Hauling Truck Capacity (yd3

): 20 (default)

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

12.1.3 Site Grading Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Excavators Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0559 0.0013 0.2269 0.5086 0.0086 0.0086 0.0050 119.70

Graders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0676 0.0014 0.3314 0.5695 0.0147 0.0147 0.0061 132.89

Other Construction Equipment Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0442 0.0012 0.2021 0.3473 0.0068 0.0068 0.0039 122.60

Rubber Tired Dozers Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.1671 0.0024 1.0824 0.6620 0.0418 0.0418 0.0150 239.45

Scrapers Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.1495 0.0026 0.8387 0.7186 0.0334 0.0334 0.0134 262.81

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0335 0.0007 0.1857 0.3586 0.0058 0.0058 0.0030 66.872

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-47

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

12.1.4 Site Grading Phase Formula(s)

- Fugitive Dust Emissions per Phase

PM10FD = (20 * ACRE * WD) / 2000

PM10FD: Fugitive Dust PM 10 Emissions (TONs)

20: Conversion Factor Acre Day to pounds (20 lb / 1 Acre Day)

ACRE: Total acres (acres)

WD: Number of Total Work Days (days)

2000: Conversion Factor pounds to tons

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = (HAOnSite + HAOffSite) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

HAOnSite: Amount of Material to be Hauled On-Site (yd3

)

HAOffSite: Amount of Material to be Hauled Off-Site (yd3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-48 GES0917191342ATL

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

12.2 Paving Phase

12.2.1 Paving Phase Timeline Assumptions

- Phase Start Date

Start Month: 2

Start Quarter: 1

Start Year: 2026

- Phase Duration

Number of Month: 4

Number of Days: 0

12.2.2 Paving Phase Assumptions

- General Paving Information

Paving Area (ft2

): 1668213

- Paving Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Pavers Composite 1 8

Paving Equipment Composite 2 8

Rollers Composite 2 6

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

12.2.3 Paving Phase Emission Factor(s)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-49

- Construction Exhaust Emission Factors (lb/hour) (default)

Excavators Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0559 0.0013 0.2269 0.5086 0.0086 0.0086 0.0050 119.70

Graders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0676 0.0014 0.3314 0.5695 0.0147 0.0147 0.0061 132.89

Other Construction Equipment Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0442 0.0012 0.2021 0.3473 0.0068 0.0068 0.0039 122.60

Rubber Tired Dozers Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.1671 0.0024 1.0824 0.6620 0.0418 0.0418 0.0150 239.45

Scrapers Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.1495 0.0026 0.8387 0.7186 0.0334 0.0334 0.0134 262.81

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0335 0.0007 0.1857 0.3586 0.0058 0.0058 0.0030 66.872

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

12.2.4 Paving Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = PA * 0.25 * (1 / 27) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

PA: Paving Area (ft2

)

0.25: Thickness of Paving Area (ft)

(1 / 27): Conversion Factor cubic feet to cubic yards ( 1 yd3 / 27 ft3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-50 GES0917191342ATL

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCP = (2.62 * PA) / 43560

VOCP: Paving VOC Emissions (TONs)

2.62: Emission Factor (lb/acre)

PA: Paving Area (ft2

)

43560: Conversion Factor square feet to acre (43560 ft2 / acre)2 / acre)

13. Construction / Demolition

13.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Multipurpose Amenities

- Activity Description:

- Activity Start Date

Start Month: 6

Start Month: 2026

- Activity End Date

Indefinite: False

End Month: 9
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-51

End Month: 2026

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 0.084991 PM 2.5 0.019896

SOx 0.001355 Pb 0.000000

NOx 0.461502 NH3 0.000345

CO 0.608564 CO2e 133.8

PM 10 0.577000

13.1 Site Grading Phase

13.1.1 Site Grading Phase Timeline Assumptions

- Phase Start Date

Start Month: 6

Start Quarter: 1

Start Year: 2026

- Phase Duration

Number of Month: 2

Number of Days: 0

13.1.2 Site Grading Phase Assumptions

- General Site Grading Information

Area of Site to be Graded (ft2

): 28000

Amount of Material to be Hauled On-Site (yd3

): 0

Amount of Material to be Hauled Off-Site (yd3

): 0

- Site Grading Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Graders Composite 1 6

Other Construction Equipment Composite 1 8

Rubber Tired Dozers Composite 1 6

Tractors/Loaders/Backhoes Composite 1 7

- Vehicle Exhaust

Average Hauling Truck Capacity (yd3

): 20 (default)

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-52 GES0917191342ATL

POVs 50.00 50.00 0 0 0 0 0

13.1.3 Site Grading Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Graders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0676 0.0014 0.3314 0.5695 0.0147 0.0147 0.0061 132.89

Other Construction Equipment Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0442 0.0012 0.2021 0.3473 0.0068 0.0068 0.0039 122.60

Rubber Tired Dozers Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.1671 0.0024 1.0824 0.6620 0.0418 0.0418 0.0150 239.45

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0335 0.0007 0.1857 0.3586 0.0058 0.0058 0.0030 66.872

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

13.1.4 Site Grading Phase Formula(s)

- Fugitive Dust Emissions per Phase

PM10FD = (20 * ACRE * WD) / 2000

PM10FD: Fugitive Dust PM 10 Emissions (TONs)

20: Conversion Factor Acre Day to pounds (20 lb / 1 Acre Day)

ACRE: Total acres (acres)

WD: Number of Total Work Days (days)

2000: Conversion Factor pounds to tons

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = (HAOnSite + HAOffSite) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

HAOnSite: Amount of Material to be Hauled On-Site (yd3

)

HAOffSite: Amount of Material to be Hauled Off-Site (yd3

)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-53

HC: Average Hauling Truck Capacity (yd3)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

13.2 Paving Phase

13.2.1 Paving Phase Timeline Assumptions

- Phase Start Date

Start Month: 8

Start Quarter: 1

Start Year: 2026

- Phase Duration

Number of Month: 2

Number of Days: 0

13.2.2 Paving Phase Assumptions

- General Paving Information

Paving Area (ft2

): 28000

- Paving Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D1-54 GES0917191342ATL

Cement and Mortar Mixers Composite 4 6

Pavers Composite 1 7

Paving Equipment Composite 1 8

Rollers Composite 1 7

Tractors/Loaders/Backhoes Composite 1 7

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

13.2.3 Paving Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Graders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0676 0.0014 0.3314 0.5695 0.0147 0.0147 0.0061 132.89

Other Construction Equipment Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0442 0.0012 0.2021 0.3473 0.0068 0.0068 0.0039 122.60

Rubber Tired Dozers Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.1671 0.0024 1.0824 0.6620 0.0418 0.0418 0.0150 239.45

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0335 0.0007 0.1857 0.3586 0.0058 0.0058 0.0030 66.872

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

13.2.4 Paving Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D1-55

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = PA * 0.25 * (1 / 27) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

PA: Paving Area (ft2

)

0.25: Thickness of Paving Area (ft)

(1 / 27): Conversion Factor cubic feet to cubic yards ( 1 yd3 / 27 ft3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCP = (2.62 * PA) / 43560

VOCP: Paving VOC Emissions (TONs)

2.62: Emission Factor (lb/acre)

PA: Paving Area (ft2

)

43560: Conversion Factor square feet to acre (43560 ft2 / acre)2 / acre)
APPENDIX D – AIR CONFORMITY APPLICABILITY MODEL REPORT

RECORD OF AIR ANALYSIS (ROAA)

GES0917191342ATL D2-1

ALTERNATIVE 1

AIR CONFORMITY APPLICABILITY MODEL REPORT

RECORD OF AIR ANALYSIS (ROAA)

1. General Information: The Air Force’s Air Conformity Applicability Model (ACAM) was used to perform an 

analysis to assess the potential air quality impact/s associated with the action in accordance with the Air Force Instruction 32-

7040, Air Quality Compliance And Resource Management; the Environmental Impact Analysis Process (EIAP, 32 CFR 989); 

and the General Conformity Rule (GCR, 40 CFR 93 Subpart B). This report provides a summary of the ACAM analysis.

a. Action Location:

Base: USAG-Miami

County(s): Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

b. Action Title: USAG-Miami Housing Development

c. Project Number/s (if applicable):

d. Projected Action Start Date: 10 / 2023

e. Action Description:

USAG-Miami Housing Development

f. Point of Contact:

Name: Caitlin Santinelli

Title: Scientist

Organization: Jacobs

Email: caitlin.santinelli@jacobs.com

Phone Number: 678-530-4148

2. Air Impact Analysis: Based on the attainment status at the action location, the requirements of the General 

Conformity Rule are:

_____ applicable

__X__ not applicable

Total combined direct and indirect emissions associated with the action were estimated through ACAM on a calendar-year 

basis for the “worst-case” and “steady state” (net gain/loss upon action fully implemented) emissions.

“Air Quality Indicators” were used to provide an indication of the significance of potential impacts to air quality. These air 

quality indicators are EPA General Conformity Rule (GCR) thresholds (de minimis levels) that are applied out of context to 

their intended use. Therefore, these indicators do not trigger a regulatory requirement; however, they provide a warning that the 

action is potentially significant. It is important to note that these indicators only provide a clue to the potential impacts to air 

quality.

Given the GCR de minimis threshold values are the maximum net change an action can acceptably emit in non-attainment and 

maintenance areas, these threshold values would also conservatively indicate an actions emissions within an attainment would 

also be acceptable. An air quality indicator value of 100 tons/yr is used based on the GCR de minimis threshold for the least 

severe non-attainment classification for all criteria pollutants (see 40 CFR 93.153). Therefore, the worst-case year emissions 

were compared against the GCR Indicator and are summarized below.
APPENDIX D – AIR CONFORMITY APPLICABILITY MODEL REPORT

RECORD OF AIR ANALYSIS (ROAA)

D2-2 GES0917191342ATL

Analysis Summary:

2023

Pollutant Action Emissions (ton/yr) AIR QUALITY INDICATOR

Threshold (ton/yr) Exceedance (Yes or No)

NOT IN A REGULATORY AREA

VOC 0.065 100 No

NOx 0.349 100 No

CO 0.519 100 No

SOx 0.001 100 No

PM 10 0.012 100 No

PM 2.5 0.012 100 No

Pb 0.000 100 No

NH3 0.000 100 No

CO2e 122.8

2024

Pollutant Action Emissions (ton/yr) AIR QUALITY INDICATOR

Threshold (ton/yr) Exceedance (Yes or No)

NOT IN A REGULATORY AREA

VOC 1.543 100 No

NOx 2.602 100 No

CO 3.744 100 No

SOx 0.008 100 No

PM 10 0.098 100 No

PM 2.5 0.098 100 No

Pb 0.000 100 No

NH3 0.003 100 No

CO2e 762.2

2025

Pollutant Action Emissions (ton/yr) AIR QUALITY INDICATOR

Threshold (ton/yr) Exceedance (Yes or No)

NOT IN A REGULATORY AREA

VOC 3.965 100 No

NOx 15.157 100 No

CO 9.701 100 No

SOx 0.051 100 No

PM 10 93.536 100 No

PM 2.5 0.584 100 No

Pb 0.000 100 No

NH3 0.078 100 No

CO2e 5534.7

2026

Pollutant Action Emissions 

(ton/yr)

AIR QUALITY INDICATOR

Threshold (ton/yr) Exceedance (Yes or No)

NOT IN A REGULATORY AREA

VOC 1.609 100 No

NOx 13.589 100 No

CO 7.246 100 No

SOx 0.045 100 No

PM 10 49.882 100 No
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D2-3

PM 2.5 0.537 100 No

Pb 0.000 100 No

NH3 0.077 100 No

CO2e 4911.2

2027 - (Steady State)

Pollutant Action Emissions (ton/yr) AIR QUALITY INDICATOR

Threshold (ton/yr) Exceedance (Yes or No)

NOT IN A REGULATORY AREA

VOC 0.000 100 No

NOx 0.000 100 No

CO 0.000 100 No

SOx 0.000 100 No

PM 10 0.000 100 No

PM 2.5 0.000 100 No

Pb 0.000 100 No

NH3 0.000 100 No

CO2e 0.0

None of estimated emissions associated with this action are above the GCR indicators, indicating no significant impact to 

air quality; therefore, no further air assessment is needed.

___________________________________________________________ __________________

Caitlin Santinelli, Scientist DATE
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D3-1

ALTERNATIVE 2

DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

1. General Information

- Action Location

Base: USAG-Miami

County(s): Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Action Title: USAG-Miami Mixed Use Property

- Project Number/s (if applicable):

- Projected Action Start Date: 1 / 2024

- Action Purpose and Need:

USAG-Miami Housing Development - Mixed Use Property

- Action Description:

USAG-Miami Housing Development - Mixed Use Property

- Point of Contact

Name: Caitlin Santinelli

Title: Scientist

Organization: Jacobs

Email: caitlin.santinelli@jacobs.com

Phone Number: 678-530-4148

- Activity List:

Activity Type Activity Title

2. Construction / Demolition Mixed Use Property

2. Construction / Demolition

2.1 General Information & Timeline Assumptions

- Activity Location

County: Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

- Activity Title: Mixed Use Property

- Activity Description:

- Activity Start Date

Start Month: 1

Start Month: 2024

- Activity End Date

Indefinite: False

End Month: 12
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D3-2 GES0917191342ATL

End Month: 2024

- Activity Emissions:

Pollutant Total Emissions (TONs) Pollutant Total Emissions (TONs)

VOC 3.765667 PM 2.5 0.159084

SOx 0.012841 Pb 0.000000

NOx 3.975734 NH3 0.011777

CO 4.507029 CO2e 1311.8

PM 10 0.163890

2.1 Building Construction Phase

2.1.1 Building Construction Phase Timeline Assumptions

- Phase Start Date

Start Month: 1

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 12

Number of Days: 0

2.1.2 Building Construction Phase Assumptions

- General Building Construction Information

Building Category: Commercial or Retail

Area of Building (ft2

): 906000

Height of Building (ft): 45

Number of Units: N/A

- Building Construction Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cranes Composite 1 7

Forklifts Composite 3 8

Generator Sets Composite 1 8

Tractors/Loaders/Backhoes Composite 3 7

Welders Composite 1 8

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D3-3

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

- Vendor Trips

Average Vendor Round Trip Commute (mile): 40 (default)

- Vendor Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

2.1.3 Building Construction Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

Cranes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0715 0.0013 0.4600 0.3758 0.0161 0.0161 0.0064 128.78

Forklifts Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0246 0.0006 0.0973 0.2146 0.0029 0.0029 0.0022 54.451

Generator Sets Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0303 0.0006 0.2464 0.2674 0.0091 0.0091 0.0027 61.061

Tractors/Loaders/Backhoes Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0348 0.0007 0.1980 0.3589 0.0068 0.0068 0.0031 66.875

Welders Composite

VOC SOx NOx CO PM 10 PM 2.5 CH4 CO2e

Emission Factors 0.0227 0.0003 0.1427 0.1752 0.0059 0.0059 0.0020 25.653

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

2.1.4 Building Construction Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D3-4 GES0917191342ATL

- Vehicle Exhaust Emissions per Phase

VMTVE = BA * BH * (0.32 / 1000) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.32 / 1000): Conversion Factor ft3 to trips (0.32 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Vender Trips Emissions per Phase

VMTVT = BA * BH * (0.05 / 1000) * HT

VMTVT: Vender Trips Vehicle Miles Travel (miles)

BA: Area of Building (ft2

)

BH: Height of Building (ft)

(0.05 / 1000): Conversion Factor ft3 to trips (0.05 trip / 1000 ft3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVT: Vender Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D3-5

2.2 Architectural Coatings Phase

2.2.1 Architectural Coatings Phase Timeline Assumptions

- Phase Start Date

Start Month: 10

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 3

Number of Days: 0

2.2.2 Architectural Coatings Phase Assumptions

- General Architectural Coatings Information

Building Category: Non-Residential

Total Square Footage (ft2

): 270700

Number of Units: N/A

- Architectural Coatings Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

2.2.3 Architectural Coatings Phase Emission Factor(s)

- Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.282 000.002 000.207 003.392 000.006 000.005 000.023 00341.791

LDGT 000.376 000.003 000.373 004.889 000.007 000.006 000.024 00439.705

HDGV 000.832 000.005 000.964 016.217 000.016 000.014 000.046 00814.851

LDDV 000.084 000.003 000.127 002.822 000.004 000.004 000.008 00334.379

LDDT 000.227 000.004 000.365 004.850 000.007 000.006 000.008 00473.628

HDDV 000.423 000.014 004.175 001.653 000.176 000.162 000.028 01559.331

MC 003.040 000.003 000.626 013.017 000.026 000.023 000.052 00392.775

2.2.4 Architectural Coatings Phase Formula(s)

- Worker Trips Emissions per Phase

VMTWT = (1 * WT * PA) / 800

VMTWT: Worker Trips Vehicle Miles Travel (miles)

1: Conversion Factor man days to trips ( 1 trip / 1 man * day)

WT: Average Worker Round Trip Commute (mile)

PA: Paint Area (ft2

)

800: Conversion Factor square feet to man days ( 1 ft2 / 1 man * day)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D3-6 GES0917191342ATL

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTWT: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCAC = (AB * 2.0 * 0.0116) / 2000.0

VOCAC: Architectural Coating VOC Emissions (TONs)

BA: Area of Building (ft2

)

2.0: Conversion Factor total area to coated area (2.0 ft2 coated area / total area)

0.0116: Emission Factor (lb/ft2

)

2000: Conversion Factor pounds to tons

2.3 Paving Phase

2.3.1 Paving Phase Timeline Assumptions

- Phase Start Date

Start Month: 3

Start Quarter: 1

Start Year: 2024

- Phase Duration

Number of Month: 6

Number of Days: 0

2.3.2 Paving Phase Assumptions

- General Paving Information

Paving Area (ft2

): 335200

- Paving Default Settings

Default Settings Used: Yes

Average Day(s) worked per week: 5 (default)

- Construction Exhaust (default)

Equipment Name Number Of 

Equipment

Hours Per Day

Cement and Mortar Mixers Composite 4 6

Pavers Composite 1 8

Paving Equipment Composite 2 6

Rollers Composite 2 6

Tractors/Loaders/Backhoes Composite 1 7

- Vehicle Exhaust

Average Hauling Truck Round Trip Commute (mile): 20 (default)

- Vehicle Exhaust Vehicle Mixture (%)

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 0 0 0 0 0 100.00 0

- Worker Trips

Average Worker Round Trip Commute (mile): 20 (default)

- Worker Trips Vehicle Mixture (%)
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

GES0917191342ATL D3-7

LDGV LDGT HDGV LDDV LDDT HDDV MC

POVs 50.00 50.00 0 0 0 0 0

2.3.3 Paving Phase Emission Factor(s)

- Construction Exhaust Emission Factors (lb/hour) (default)

- Vehicle Exhaust & Worker Trips Emission Factors (grams/mile)

VOC SOx NOx CO PM 10 PM 2.5 Pb NH3 CO2e

LDGV 000.578 000.008 000.613 005.086 000.009 000.008 000.034 00391.932

LDGT 000.823 000.010 001.060 008.566 000.010 000.009 000.034 00522.586

HDGV 001.597 000.016 002.785 026.982 000.023 000.020 000.046 00814.010

LDDV 000.216 000.004 000.307 004.001 000.006 000.006 000.008 00402.372

LDDT 000.537 000.006 000.822 008.176 000.008 000.008 000.008 00626.077

HDDV 000.762 000.015 007.639 002.810 000.395 000.363 000.028 01633.017

MC 003.190 000.008 000.648 014.785 000.027 000.024 000.048 00392.026

2.3.4 Paving Phase Formula(s)

- Construction Exhaust Emissions per Phase

CEEPOL = (NE * WD * H * EFPOL) / 2000

CEEPOL: Construction Exhaust Emissions (TONs)

NE: Number of Equipment

WD: Number of Total Work Days (days)

H: Hours Worked per Day (hours)

EFPOL: Emission Factor for Pollutant (lb/hour)

2000: Conversion Factor pounds to tons

- Vehicle Exhaust Emissions per Phase

VMTVE = PA * 0.25 * (1 / 27) * (1 / HC) * HT

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

PA: Paving Area (ft2

)

0.25: Thickness of Paving Area (ft)

(1 / 27): Conversion Factor cubic feet to cubic yards ( 1 yd3 / 27 ft3

)

HC: Average Hauling Truck Capacity (yd3

)

(1 / HC): Conversion Factor cubic yards to trips (1 trip / HC yd3

)

HT: Average Hauling Truck Round Trip Commute (mile/trip)

VPOL = (VMTVE * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Vehicle Exhaust Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Vehicle Exhaust On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D3-8 GES0917191342ATL

- Worker Trips Emissions per Phase

VMTWT = WD * WT * 1.25 * NE

VMTWT: Worker Trips Vehicle Miles Travel (miles)

WD: Number of Total Work Days (days)

WT: Average Worker Round Trip Commute (mile)

1.25: Conversion Factor Number of Construction Equipment to Number of Works

NE: Number of Construction Equipment

VPOL = (VMTWT * 0.002205 * EFPOL * VM) / 2000

VPOL: Vehicle Emissions (TONs)

VMTVE: Worker Trips Vehicle Miles Travel (miles)

0.002205: Conversion Factor grams to pounds

EFPOL: Emission Factor for Pollutant (grams/mile)

VM: Worker Trips On Road Vehicle Mixture (%)

2000: Conversion Factor pounds to tons

- Off-Gassing Emissions per Phase

VOCP = (2.62 * PA) / 43560

VOCP: Paving VOC Emissions (TONs)

2.62: Emission Factor (lb/acre)

PA: Paving Area (ft2

)

43560: Conversion Factor square feet to acre (43560 ft2 / acre)2 / acre)
APPENDIX D – AIR CONFORMITY APPLICABILITY MODEL REPORT

RECORD OF AIR ANALYSIS (ROAA)

GES0917191342ATL D4-1

ALTERNATIVE 2

AIR CONFORMITY APPLICABILITY MODEL REPORT

RECORD OF AIR ANALYSIS (ROAA)

1. General Information: The Air Force’s Air Conformity Applicability Model (ACAM) was used to perform an 

analysis to assess the potential air quality impact/s associated with the action in accordance with the Air Force Instruction 32-

7040, Air Quality Compliance And Resource Management; the Environmental Impact Analysis Process (EIAP, 32 CFR 989); 

and the General Conformity Rule (GCR, 40 CFR 93 Subpart B). This report provides a summary of the ACAM analysis.

a. Action Location:

Base: USAG-Miami

County(s): Miami-Dade

Regulatory Area(s): NOT IN A REGULATORY AREA

b. Action Title: USAG-Miami Mixed Use Property

c. Project Number/s (if applicable):

d. Projected Action Start Date: 1 / 2024

e. Action Description:

USAG-Miami Housing Development - Mixed Use Property

f. Point of Contact:

Name: Caitlin Santinelli

Title: Scientist

Organization: Jacobs

Email: caitlin.santinelli@jacobs.com

Phone Number: 678-530-4148

2. Air Impact Analysis: Based on the attainment status at the action location, the requirements of the General 

Conformity Rule are:

_____ applicable

__X__ not applicable

Total combined direct and indirect emissions associated with the action were estimated through ACAM on a calendar-year 

basis for the “worst-case” and “steady state” (net gain/loss upon action fully implemented) emissions.

“Air Quality Indicators” were used to provide an indication of the significance of potential impacts to air quality. These air 

quality indicators are EPA General Conformity Rule (GCR) thresholds (de minimis levels) that are applied out of context to 

their intended use. Therefore, these indicators do not trigger a regulatory requirement; however, they provide a warning that the 

action is potentially significant. It is important to note that these indicators only provide a clue to the potential impacts to air 

quality.

Given the GCR de minimis threshold values are the maximum net change an action can acceptably emit in non-attainment and 

maintenance areas, these threshold values would also conservatively indicate an actions emissions within an attainment would 

also be acceptable. An air quality indicator value of 100 tons/yr is used based on the GCR de minimis threshold for the least 

severe non-attainment classification for all criteria pollutants (see 40 CFR 93.153). Therefore, the worst-case year emissions 

were compared against the GCR Indicator and are summarized below.
APPENDIX D – DETAIL AIR CONFORMITY APPLICABILITY MODEL REPORT

D4-2 GES0917191342ATL

Analysis Summary:

2024

Pollutant Action Emissions (ton/yr) AIR QUALITY INDICATOR

Threshold (ton/yr) Exceedance (Yes or No)

NOT IN A REGULATORY AREA

VOC 3.766 100 No

NOx 3.976 100 No

CO 4.507 100 No

SOx 0.013 100 No

PM 10 0.164 100 No

PM 2.5 0.159 100 No

Pb 0.000 100 No

NH3 0.012 100 No

CO2e 1311.8

2025 - (Steady State)

Pollutant Action Emissions (ton/yr) AIR QUALITY INDICATOR

Threshold (ton/yr) Exceedance (Yes or No)

NOT IN A REGULATORY AREA

VOC 0.000 100 No

NOx 0.000 100 No

CO 0.000 100 No

SOx 0.000 100 No

PM 10 0.000 100 No

PM 2.5 0.000 100 No

Pb 0.000 100 No

NH3 0.000 100 No

CO2e 0.0

None of estimated emissions associated with this action are above the GCR indicators, indicating no significant impact to 

air quality; therefore, no further air assessment is needed.

___________________________________________________________ __________________

Caitlin Santinelli, Scientist DATE
Appendix E

Special-status Species Descriptions
E-1

APPENDIX E

Special-status Species Descriptions

Plants

Blodgett’s Silverbush (Argythamnia blodgettii)

The Blodgett’s silverbush is a perennial herb in the Spurge (Euphorbiaceae) family that is federally threatened and 

Florida endangered. This species reaches 2 feet tall and has 0.6- to 1.6-inch-long leaves and small, white flowers 

that grow in leaf axils along the stems. Flowering occurs year-round. Blodgett’s silverbush is endemic to MiamiDade and Monroe counties in Florida where it occurs in low, moist limestone areas near the margins of pine 

rocklands and in sunny edges and gaps in pine rocklands, rockland hammocks, and coastal berm habitats 

(NatureServe, 2019). There is no suitable habitat for this species within the project area; therefore, it is not 

expected to occur within the project area.

Crenulate Lead-plant (Amorpha crenulata)

The crenulate lead-plant is a perennial, deciduous shrub in the Pea (Fabaceae) family that is federally endangered 

and Florida endangered. This species reaches 5 feet tall and has reddish-purple branches, 0.5- to 1.5-inch-long 

leaves, and 6- to 8-inch-long flower spikes (FNAI, 2000a). Crenulate tarplant is endemic to Miami-Dade County in 

Florida where it occurs on poorly drained Opalocka sands within pine rocklands or in wet prairies with Opalockarock outcrop complex soils (USFWS, 1999a). There is no suitable habitat for this species within the project area; 

therefore, it is not expected to occur within the project area.

Florida Brickell-bush (Brickellia mosieri)

The Florida Brickell-bush is a perennial herb in the Aster (Asteraceae) family that is federally endangered and 

Florida endangered. This species reaches 1 to 3.5 feet tall and has 0.4- to 1.2-inch-long leaves and white disk 

flowers that grow in small, dense heads. Flowering occurs primarily between August and October. Florida Brickellbush is endemic to Miami-Dade County where it occurs in pine rocklands with open shrub layer, exposed 

limestone, and minimal leaf litter (FNAI, 2000b). There is no suitable habitat for this species within the project 

area; therefore, it is not expected to occur within the project area. 

Deltoid Spurge (Chamaesyce deltoidea ssp. deltoidea)

The deltoid spurge is a prostrate, perennial herb in the Spurge (Euphorbiaceae) family that is federally 

endangered and Florida endangered. This species forms mats up to 6 inches wide and has 0.25-inch-long leaves 

and flowers that occur singly, in leaf axils. Flowering happens between November and May. Deltoid spurge is 

endemic to Miami-Dade County in Florida where it is found in areas of pine rocklands with an open shrub canopy, 

exposed limestone, and minimal leaf litter (USFWS, 1999b). There is no suitable habitat for this species within the 

project area; therefore, it is not expected to occur within the project area.

Garber’s Spurge (Chamaesyce garberi)

The Garber’s spurge is a perennial herb in the Spurge (Euphorbiaceae) family that is federally endangered and 

Florida endangered. This species has stems up to 12 inches long, leaves to 0.5 inch long, and single flowers held by 

cyathia in leaf axils. Garber’s spurge is endemic to Miami-Dade and Monroe counties in Florida where it occurs on

thin, sandy soils composed mostly of Pamlico sands or directly on limestone in a variety of open to moderately 

shaded habitat types (USFWS, 1999c). There is no suitable habitat for this species within the project area; 

therefore, it is not expected to occur within the project area.
APPENDIX E—SPECIAL-STATUS SPECIES DESCRIPTIONS

E-2

Pineland Sandmat (Chamaesyce deltoidea pinetorum)

The pineland sandmat is a perennial herb in the Spurge (Euphorbiaceae) family that is federally threatened and 

Florida endangered. This species forms mats up to 6 inches wide and has erect stems, 0.25-inch-long leaves with 

straight, spreading hairs, and flowers that occur singly, in leaf axils. Flowering occurs April through November. 

Pineland sandmat is endemic to Miami-Dade County in Florida where it occurs on calcareous soils in pine 

rocklands on the Miami Rock Ridge (FNAI, 2000c). There is no suitable habitat for this species within the project 

area; therefore, it is not expected to occur within the project area.

Cape Sable Thoroughwort (Chromolaena frustrata)

The Cape Sable thoroughwort is a perennial herb in the Aster (Asteraceae) family that is federally endangered and 

Florida endangered. This species is 8 to 40 inches in height with hairy stems, 0.6- to 1.6-inch-long leaves, and 

flower heads on long stalks at the ends of branches. Flowering occurs year-round. Cape Sable thoroughwort is 

endemic to Monroe County in Florida where it occurs on coastal rock barrens and berms and on sunny edges of 

rockland hammocks (FNAI, 2000d). There are currently only four or five known protected occurrences of this 

species; therefore, it is not expected to occur within the project area.

Florida Semaphore Cactus (Consolea corallicola)

The Florida semaphore cactus is a perennial shrub in the Cactus (Cactaceae) family that is federally endangered 

and Florida endangered. This species is an erect cactus that reaches 3 to 15 feet in height and has 1- to 4-inchlong spines. Older branches (pads, joints) are two to four times as long as they are wide and held at right angles to 

the ground. Young joints are cylindrical with fruits or flowers at their tips. Flowering can occur year-round, but 

primarily between December and April (FNAI, 2000e). Florida semaphore cactus is endemic to Monroe County in 

Florida where it is known only from a few sites in the Florida Keys. It occurs on bare rocks with only a slight 

covering of humus in the hardwood hammocks near sea level (NatureServe, 2019). There is no suitable habitat for 

this species within the project area; therefore, it is not expected to occur within the project area. 

Okeechobee Gourd (Cucurbita okeechobeensis ssp. okeechobeensis)

The Okeechobee gourd is an annual or perennial vine in the Gourd (Cucurbitaceae) family that is federally 

endangered and Florida endangered. This species is a high-climbing vine with tendrils, heart- to kidney-shaped 

leaf blades, and cream-colored flowers that are bell-shaped, forms mats up to 6 inches wide and has erect stems, 

0.25-inch-long leaves with straight, spreading hairs, and flowers that occur singly, in leaf axils (USFWS, 1999d). 

Flowering occurs in the spring and summer. Okeechobee gourd is endemic to Glades and Palm Beach counties

where it occurs in pond apple swamps and mucky soils on Lake Okeechobee shores and islands and in floodplain 

forests along the St. Johns River (FNAI, 2000f). There is no suitable habitat for this species within the project area; 

therefore, it is not expected to occur within the project area.

Florida Prairie-clover (Dalea carthagenensis floridana)

The Florida prairie-clover is a perennial shrub in the Pea (Fabaceae) family that is federally endangered and

Florida endangered. This species has a woody base and red, contorted, velvety, non-woody branches that grow to 

6 feet tall. Leaves consist of 11 to 23 oval, gland-tipped leaflets, and whitish flowers occur in small, loose heads at 

the ends of hairy, glandular stalks. Flowering occurs year-round. Florida prairie-clover is endemic to Miami-Dade, 

Monroe, and Palm Beach counties in Florida where it occurs in pine rocklands, edges of rockland hammocks, 

coastal uplands, and marl prairie (FNAI, 2000g). There is no suitable habitat for this species within the project 

area; therefore, it is not expected to occur within the project area.
APPENDIX E—SPECIAL-STATUS SPECIES DESCRIPTIONS

E-3

Florida Pineland Crabgrass (Digitaria pauciflora)

The Florida pineland crabgrass is a perennial herb in the Grass (Poaceae) family that is federally threatened and 

Florida endangered. This species is a clump-forming grass with stems and leaves that are covered with soft white 

hairs. Culms are 1.6 to 3.3 feet tall, leaves are blue-green, and flowers are dull green and borne in small, wiry 

spikes. Florida pineland crabgrass is endemic to Miami-Dade and Monroe counties in Florida where it occurs in 

pine rocklands and the open ecotone between grassy marl prairie and pine rockland communities (NatureServe, 

2019). This species is currently only known to occur at one site in Everglades National Park. There is no suitable 

habitat for this species within the project area; therefore, it is not expected to occur within the project area.

Small’s Milkpea (Galactia smallii)

Small’s milkpea is a perennial herb in the Pea (Fabaceae) family that is federally endangered and Florida 

endangered. This species has trailing stems up to 6 feet long, leaves less than 1 inch long that consist of three 

broadly oval leaflets, and typical pink/purple pea flowers that are about 0.5 inch long and grow in clusters of 1 to 

5 at the ends of stems or on stalks. Flowering occurs a few weeks following fire, primarily in the summer. Small’s 

milkpea is endemic to Miami-Dade County where it occurs on Redland pine rocklands (FNAI, 2000h). There is no 

suitable habitat for this species within the project area; therefore, it is not expected to occur within the project 

area.

Beach Jacquemontia (Jacquemontia reclinata)

The beach jacquemontia is a perennial vine in the Morning Glory (Convolvulaceae) family that is federally 

endangered and Florida endangered. This species has a woody base with non-woody, creeping or twinning stems 

up to 6 feet long. Leaves are about 1 inch long and the white flowers are 1 inch across with 5 lobes. Flowering 

occurs between November and May (FNAI, 2000i). Beach clustervine is endemic to Broward, Miami-Dade, and 

Palm Beach counties in Florida where it occurs on moist, well-drained sandy soils without a humusy top layer in 

dunes and disturbed openings in maritime hammock, coastal strand, and coastal scrub (NatureServe, 2019; IRC, 

2016). There is no suitable habitat for this species within the project area; therefore, it is not expected to occur 

within the project area.

Sand Flax (Linum arenicola)

Sand flax is a perennial herb in the Flax (Linaceae) family that is federally endangered and Florida endangered. 

This species has wiry stems reaching up to 28 inches tall. Leaves are few, alternate, and early deciduous. Flowers 

are in terminal cymes, five-parted, less than 2.5 inches wide, with ephemeral yellow petals and separate styles.

Sand flax is endemic to Miami-Dade and Monroe counties where it occurs in pine rockland, marl prairie habitats 

which require periodic wildfires to maintain an open, shrub-free subcanopy and reduce litter levels. Only small 

and isolated occurrences remain in a restricted range of southern Florida and the Florida Keys (USFWS, 2015a).

There is no suitable habitat for this species within the project area; therefore, it is not expected to occur within 

the project area.

Carter’s Small-flowered Flax (Linum carteri)

The Carter’s flax is an annual herb in the Flax (Linaceae) family that is federally endangered and Florida 

endangered. This species is 2 to 24 inches tall with 0.4- to 1.2-inch-long narrow leaves and 0.5-inch-wide yelloworange flowers. Flowering occurs between February and May. Carter’s flax is endemic to Miami-Dade County in 

Florida where it occurs in pine rocklands (FNAI, 2000j). There is no suitable habitat for this species within the 

project area; therefore, it is not expected to occur within the project area.
APPENDIX E—SPECIAL-STATUS SPECIES DESCRIPTIONS

E-4

Tiny Polygala (Polygala smallii)

The tiny polygala is a perennial herb in the Milkwort (Polygalaceae) family that is federally endangered and Florida 

endangered. This species has one to four, typically unbranched stems that are about 4 inches tall. Leaves are 0.5 

inch wide and 2 inches long and flowers are small and numerous in a yellow-green crowded head at the top of the 

stem. Flowering occurs year-round. Tiny polygala is endemic to Broward, Martin, Miami-Dade, and Palm Beach 

counties in Florida where it occurs in pine rockland, scrub, and sandhill habitats and in open coastal spoil piles 

(FNAI, 2000k). There is no suitable habitat for this species within the project area; therefore, it is not expected to 

occur within the project area.

Everglades Bully (Sideroxylon reclinatum ssp. austrofloridense)

The Everglades bully is a perennial shrub in the Sapodilla (Sapotaceae) family that is federally threatened. This 

species is deciduous and thorny with leaves less than 2.8 inches long and flowers in axillary cymes. Everglades 

bully is endemic to Miami-Dade and Monroe counties in Florida where it occurs in pine rockland and marl prairie 

habitats (NatureServe, 2019). There is no suitable habitat for this species within the project area; therefore, it is 

not expected to occur within the project area. 

Florida Bristle Fern (Trichomanes punctatum ssp. floridanum)

The Florida bristle fern is a perennial herb in the Filmy Fern (Hymenophyllaceae) family that is federally 

endangered and Florida endangered. This species has long-creeping, thread-like stems with filmy and delicate 

leaves less than 1 inch long. Florida bristle fern is endemic to Florida where it occurs on tree trunks in hammocks, 

edges of limesinks, and limestone boulders (FNAI, 2000l). There is no suitable habitat for this species within the 

project area; therefore, it is not expected to occur within the project area. 

Carter’s Mustard (Warea carteri)

The Carter’s mustard is an annual herb in the Mustard (Brassicaceae) family that is federally endangered and 

Florida endangered. This species is up to 40 inches tall with many slender, branching stems that form a rounded 

crown. Leaves are about 2 inches long near the base of the stem and decrease in size as they move upwards. 

Flowers are white, grow in rounded clusters, and bloom September through October. Carter’s mustard is endemic 

to south and central Florida where it occurs after fire in sandhill, scrubby flatwoods, and inland and coastal scrub 

habitats (FNAI, 2000m). There is no suitable habitat for this species within the project area; therefore, it is not 

expected to occur within the project area.

Birds

Bachman’s Warbler (Vermivora bachmanii)

The Bachman’s warbler is a federally endangered and MBTA-protected migratory species. This species bred 

formerly in southeastern U.S. and wintered in Cuba and Isle of Pines. The last confirmed sightings of Bachman’s 

warbler were near Charleston, South Carolina in 1961. Nesting habitats are thought to include trees associated 

with headwater swamps, wet flats and bottomland hardwoods. Other possible nesting sites could include oldgrown stands of bottomland hardwoods. Bachman’s warbler feeds primarily on insects and other small 

arthropods, favoring caterpillars and spiders during the breeding season, and mainly insects during the winter

(Hamel, 2011). This possibly extinct species is highly unlikely to occur within the proposed project area.

Cape Sable Seaside Sparrow (Ammodramus maritimus mirabilis)

The Cape Sable seaside sparrow is federally endangered and protected under the MBTA. It is one of seven 

subspecies of the seaside sparrow. It is differentiated from other subspecies by its greenish olive dorsum, white 

ventrum, and lack of a breast band. Of the seven, this subspecies prefers freshwater interior marshes of Collier, 

Monroe, and Miami-Dade counties over salt marshes. The seaside sparrow forages around smooth cordgrass 

where they probe mud for the preferred food items of beetles and spiders. Other food sources include seeds, 

insects, decapods, amphipods, and mollusks in the winter, and larva insects and amphipods in the breeding 

season (Post and Greenlaw, 2009). Breeding occurs between February and August. Habitat is located within the 
APPENDIX E—SPECIAL-STATUS SPECIES DESCRIPTIONS

E-5

Everglades National Park and Big Cypress National Preserve in seasonally inundated freshwater interior marshes 

(FNAI, 2001a). Nesting sites generally require open vegetation such as pools and creek edges so that nesting and 

feeding sites are contiguous. During non-breeding seasons, the Cape Sable seaside sparrow have an average range 

of 12 hectares, but are relatively sedentary (Post and Greenlaw, 2009). Due to a lack of suitable habitat, this 

species is highly unlikely to occur within the proposed project area.

Everglade Snail Kite (Rostrhamus sociabilis plumbeus)

The Everglade snail kite is a federally endangered and MBTA-protected nonmigratory, medium-sized raptor. This 

species inhabits large, open freshwater marshes and lakes with shallow open waters. Open water areas lacking 

emergent vegetation are required for foraging. In Florida, the Everglade snail kite is restricted to the St. Johns 

River headwaters; southwestern Lake Okeechobee; small areas in Broward, Miami-Dade, and Palm Beach 

counties; and parts of Everglades National Park, Loxahatchee National Wildlife Refuge, and Big Cypress National 

Preserve (NatureServe, 2019). The primary foraging species for this subspecies is the apple snail. The main nesting 

period is January through August. Nesting occurs over water in low trees or shrubs, such as willows, wax myrtles, 

pond apples, or buttonbushes, dahoon holly, cocoplum, Brazilian pepper, sawgrass, cat-tail, bulrush, and reed 

(FNAI, 2001b; USFWS, 1999e). Due to a lack of suitable habitat, this species is highly unlikely to occur within the 

proposed project area.

Florida Burrowing Owl (Athene cunicularia floridana)

The Florida burrowing owl is a state threatened and MBTA-protected species that resides in central and south 

Florida and on the Bahamas. This subspecies breeds in the grasslands of central and south Florida (Poulin et al., 

2011). The Florida burrowing owl is predominantly nonmigratory and maintains home ranges and territories while 

nesting. Habitats include high, sparsely vegetated, sandy ground. In addition to “natural” habitats, such as dry 

prairie and sandhills, ruderal areas such as pastures, airports, ball fields, parks, school grounds, university 

campuses, road rights-of-way, and vacant spaces in residential areas are regularly used (FNAI, 2001c). This species 

is known to occur in Doral and has a moderate potential to occur within the proposed project area.

Florida Grasshopper Sparrow (Ammodramus savannarum)

The Florida grasshopper sparrow is a federally endangered and MBTA-protected subspecies that occurs in Three 

Lakes Wildfire Management Area and Avon Park Air Force Range of Florida and does not migrate from southcentral Florida. Nesting only occurs in Florida between the months of early April and late June. Nests are built in 

shallow ground as excavations in sand substrate. This subspecies forages for insects such as grasshoppers, 

crickets, beetles, weevils, moths and their larvae as well as vegetation such as sedge seeds and star grass. Suitable

habitat consists of flat and dry prairie lands in central and south Florida with vegetation consisting of saw 

palmettos, dwarf oaks, bluestem grasses, St. John’s wort, and wiregrasses (USFWS, 1999f). Due to a lack of 

suitable habitat, this species is highly unlikely to occur within the proposed project area.

Florida Scrub-jay (Aphelocoma coerulescens)

The Florida scrub-jay is a federally threatened and MBTA-protected species. This nonmigratory species inhabits 

open areas without a dense canopy in oak scrub found on white, drained sand. The Florida scrub-jay is mostly 

restricted to scrub ridges of central, peninsular Florida, with a few occurrences on Gulf and Atlantic coastal ridges. 

This species has been extirpated from Miami-Dade County. It forages for lizards and arthropods in the spring and 

summer and acorns in fall and winter (NatureServe, 2019). Nesting occurs March through June in low, dense 

shrubs such as sand live oak, Archbold oak, and myrtle oak (Woolfenden and Fitzpatrick, 1996). Due to its current 

restricted range and a lack of suitable habitat, this species is highly unlikely to occur within the proposed project 

area.

Ivory-billed Woodpecker (Campephilus principalis)

The ivory-billed woodpecker is a federally endangered and MBTA-protected species. The historical habitat of the 

rare, and possibly extinct, ivory-billed woodpecker has been associated with bottomland swamp forests in the 

southeast United States and Cuba. Trees associated with the habitat are soft-wood species such as pines, red 

maples, sugarberry, and cabbage palmetto. This species forages for beetle larvae as its primary food source. 
APPENDIX E—SPECIAL-STATUS SPECIES DESCRIPTIONS

E-6

Nesting occurs in partly dead trees along the edges of dense swamps. The nests themselves are built in the dead 

part of the tree (Jackson, 2002). Due to a lack of suitable habitat, it is highly unlikely the Ivory-billed woodpecker 

would occur within the project area.

Kirtland’s Warbler (Setophaga kirtlandii)

The Kirtland’s warbler is a federally endangered and MBTA-protected migratory species that forages on insects, 

fruits, and flowers and nests in young jack pine forests with well-drained sandy soils in northern North America. 

This species migrates to the Bahamian archipelago for winters. Nesting occurs on the ground concealed by grasses 

and other vegetation (Mayfield, 2014). Due to a lack of suitable habitat, this species is unlikely to occur within the 

proposed project area.

Least Tern (Sternula antillarum)

The least tern is a state threatened and MBTA-protected migratory species. This species breeds widely along 

coastal beaches and major interior rivers of North America and winters broadly across marine coastlines of 

Central and South America. The least tern nests on relatively open beaches and islands that are kept free of 

vegetation by natural scouring from tidal or river action. Least tern have recently begun breeding on flat gravel 

rooftops in certain coastal areas, particularly where natural habitats have been disturbed or lost. This species 

feeds mostly on small, shallow-bodied fresh- and saltwater fish, but its diet is varied and includes small 

crustaceans and insects. Foraging occurs in shallow-water habitats or on the marine coast such as bays, lagoons, 

estuaries, river and creek mouths, tidal marshes and lakes. Inland feeding sites include rivers, streams, sloughs, 

dike fields, marshes, ponds, sand pits, and reservoirs. This species wanders widely after breeding season, 

especially in interior U.S., before migrating southward (Thompson et al., 1997). Due to a lack of suitable habitat, 

this species is unlikely to occur within the proposed project area.

Piping Plover (Charadrius melodus)

The piping plover is a federally threatened species that breeds along the northern central region of North America 

and Canada and along the northern East Coast. Piping plover winter along the southern Atlantic Coast and the 

Gulf Coast along beaches, mudflats and sandflats. Habitat for breeding is generally open sandy beaches. Nests are 

in ground in open sand, gravel and shell-covered substrates in patchy vegetation areas. Beaches and alkali flats 

are preferred during migration. The piping plover forages for washed up freshwater and marine invertebrates 

(Elliott-Smitt and Haig, 2004). Due to a lack of suitable habitat, this species is highly unlikely to occur within the 

proposed project area.

Red Knot (Calidris canutus rufa)

The rufa red knot is a federally threatened and MBTA-protected migratory species. This subspecies breeds in the 

lower latitudes of Canada and winters anywhere from the Gulf of Mexico to eastern South America. Wintering 

and migration habitats are typically muddy or sandy coastal areas. One group of red knots have been observed 

wintering in Florida (Baker et al., 2013). Due to a lack of suitable habitat, this species is highly unlikely to occur

within the proposed project area.

Red-cockaded Woodpecker (Picoides borealis)

The red-cockaded woodpecker is a federally endangered and MBTA-protected nonmigratory species. It lives in 

small, fragmented populations in the southeast where it breeds year-round. Breeding occurs in old-growth pine 

forests that have been maintained by summer fires. This species forages in the trunks of pines mainly for 

arthropods such as beetles, ants, roaches, spiders and others. Seeds and fruits can be a food source as well. 

Nesting and roosting occurs in excavated mature pines (Jackson, 1994; USFWS, 2016). Due to a lack of suitable

habitat, this species is highly unlikely to occur within the proposed project area.

Southeastern American Kestrel (Falco sparverius paulus)

The southeastern American kestrel is a Florida threatened subspecies and year-round resident of Florida. It is 

most common in peninsular Florida with sightings in the panhandle. Northern subspecies of the southeastern 

American kestrel migrate to Florida in the winters and can be confused for the Falco sparverius paulus subspecies. 
APPENDIX E—SPECIAL-STATUS SPECIES DESCRIPTIONS

E-7

The habitat for this subspecies consists of open pines, woodland edges, prairies, and pastures. Sandhill habitat is 

preferred, but flatwoods with patches of grass and bare grounds will do as well. Nesting sites include tall dead 

trees and utility poles with open surroundings. (FNAI, 2001d). There is potentially suitable habitat for this species 

within the proposed project area and it has a moderate potential to occur.

White-crowned Pigeon (Patagioenas leucocephala)

The white-crowned pigeon is a Florida threatened species that is restricted in the United States to Florida Bay, 

Biscayne Bay, and the Florida Keys. A few individuals also potentially nest inland in Monroe and Miami-Dade 

counties. This species inhabits low-lying forests with ample fruiting trees and their diet primarily consists of 

tropical hardwood fruit trees. Breeding occurs May through September (FFWCC, 2019a). Due to a lack of suitable 

habitat, this species is highly unlikely to occur within the proposed project area.

Wood Stork (Mycteria Americana)

The wood stork is a federally threatened and MBTA-protected nonmigratory species. In Florida, wood storks are 

rare to abundant in the peninsula and Big Bend, but are much rarer in the panhandle and Florida Keys. There has 

been a dramatic decline in large colonies formerly found in south Florida and smaller more numerous colonies in 

central and northern Florida are being observed more frequently. Wetlands are essential for wood stork habitat 

(FNAI, 2001e). Due to a lack of suitable habitat, this species is unlikely to occur within the proposed project area.

Invertebrates

Bartram’s Scrub-hairstreak and Florida Leafwing Butterfly

The Bartram’s scrub-hairstreak and Florida leafwing butterfly are federally endangered species. These species 

occur only within pine rocklands and pineland croton (Croton linearis) is their only known hostplant (USFWS, 

2015b). This habitat type and host plant do not occur within the proposed project area; therefore, this species is 

highly unlikely to occur.

Miami Blue Butterfly

The Miami blue butterfly is a federally endangered species that inhabits tropical hardwood hammocks, tropical 

pine rocklands, and beachside scrub in Florida. This species is no longer known to occur on the mainland of Florida 

(FFWCC, 2019b) and is highly unlikely to occur within the proposed project area.

Schaus Swallowtail Butterfly

The Schaus swallowtail is a federally endangered species that currently occurs in small numbers in the tropical 

hardwood hammock of North Key Largo and Elliot Key in Florida (USFWS, 2015c). Due to its current restricted 

range, this species is highly unlikely to occur within the proposed project area.

Stock Island Tree Snail

The Stock Island tree snail is a federally threatened species that originally occurred exclusively in hardwood 

hammocks of the Florida Keys. Due to people collecting snails, their distribution has been extended to the 

southernmost parts of mainland Florida. This species is active primarily during the May through November wet 

season and feeds on epiphytic growth on hardwood tree trunks, branches, and leaves (USFWS, 1999g). Due to a 

lack of suitable habitat, this species is unlikely to occur within the proposed project area.

Mammals

Florida Bonneted Bat (Eumops floridanus)

The federally endangered Florida bonneted bat is the largest bat species native to Florida. It is active year-round 

and does not have periods of hibernation or torpor. This bat occurs in urban/suburban areas as well as wooded 

areas in southern Florida and will use both natural and artificial habitat structures. The Florida bonneted bat 

roosts in tree hollows, tree snags, and foliage of palms. It also has been found beneath rocks, near excavations, in 
APPENDIX E—SPECIAL-STATUS SPECIES DESCRIPTIONS

E-8

rock fractures, and on limestone outcrops. In buildings, it will roost under Spanish roof tiles, but it also may roost 

in attics, rock or brick chimneys, and fireplaces (NatureServe, 2019). The Florida bonneted bat has been observed 

throughout Miami-Dade County. There are two known roost sites in Coral Gables, near the Granada golf course,

and along the Ludlam Trail. This species is unlikely to roost within the proposed project area.

Reptiles

American Crocodile (Crocodylus acutus)

The American crocodile is a federally threatened species that inhabits brackish or saltwater areas and can be 

found in ponds, coves, and creeks in mangrove swamps. Along the southern Florida coast, this species is also 

occasionally encountered in freshwater areas (FFWCC, 2019c). The American crocodile may occur in the drainage 

canals in the vicinity of the project but would not be expected to occur in the immediate project area.

American Alligator (Alligator mississippiensis)

The American alligator is a federally threatened species, due to their similarity of appearance to the American 

crocodile. The American alligator may occur in the drainage canals in the vicinity of the project but would not be 

expected to occur in the immediate project area.

Eastern Indigo Snake (Drymarchon couperi)

The Eastern indigo snake is a federally threatened species that inhabits a broad range of habitats including scrub, 

sandhill, wet prairies, and mangrove swamps. Occupied sites are often near wetlands frequently associated with 

gopher tortoise burrows. This species is active nearly year-round in southern Florida and lays eggs in May and 

June (NatureServe, 2019). Due to a lack of suitable habitat, this species is unlikely to occur within the proposed 

project area.