Next NGA West Draft EIS, St. Louis - Executive Summary

8/20/2019 Next NGA West Draft EIS, St. Louis - Executive Summary

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Executive Summary

ES-1 Introduction

The National Geospatial-Intelligence Agency (NGA) is investigating sites for the construction and operation

of the Next NGA West Campus in the greater St. Louis metropolitan area. This effort is required to replace

mission critical facilities at the current St. Louis facility (South 2nd Street facility), which have exceeded their

service life and can no longer support the technology changes required for the NGA mission.

The Kansas City District of the U.S. Army Corps of Engineers (USACE) has developed the enclosed

environmental impact statement (EIS) in accordance with the National Environmental Policy Act of 1969

(NEPA) to evaluate the social and environmental impacts associated with the construction and operation of

the Next NGA West Campus. NGA is the proponent of this action and the U.S. Air Force (USAF) is a

cooperating agency under NEPA because the USAF may be the ultimate property owner of the Next NGA

West Campus. The Federal Aviation Administration (FAA) is a coordinating agency on this action because it

participated in the purchase of the St. Clair County Site and has associated grant assurance obligations. The

FAA is also acting as the airspace authority for this EIS.

NGA will decide on a site for the construction and operation of the Next NGA West Campus. NGA will

develop the final decision on site selection after gathering information from agencies, the public, and others

through the NEPA process and by performing the environmental impact analysis shown in this EIS. NGA will

consider the information gathered during the EIS, along with other critical factors such as its ability to

perform its mission, maintain a secure environment, and meet the construction schedule. The final selection

criteria and decision will be documented in the Record of Decision (ROD), which will be distributed after

publication of the Final EIS (FEIS).

The scope of this EIS includes the potential environmental impacts caused by the proposed construction and

operation of the Next NGA West Campus in the St. Louis metropolitan area. The intent of the EIS is to

inform the NGA decision makers of the potential project impacts through a complete and objective analysis of

the alternatives. Four site alternatives that would meet the purpose and need of the project, as well as a No

Action Alternative, are considered in the analysis.

If NGA moves from its existing location, the current property owner, the USAF, in conjunction with the NGAand General Services Administration, will be responsible for addressing the future use of the vacated South

2nd Street facilities. Insufficient information is available to discuss possible future uses of the South 2nd Street

facilities at this time; therefore, use of these facilities after NGA vacates is not part of this EIS. The USAF will

prepare the necessary NEPA documentation and conduct the National Historic Preservation Act Section 106

consultation for the future use of the South 2nd Street facilities when potential alternative uses have been

identified.


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ES-2 Purpose and Need for Action

ES-2.1 Purpose

The purpose of Next NGA West Campus is to enhance current and future missions, improve resiliency, and

resolve security challenges associated with the South 2nd Street facilities. Challenges associated with the

South 2nd Street facilities include the proximity to floodplains and incompatible adjacent industrial activities,

as well as the age and physical setting of the existing buildings, which limit NGA’s ability to economically

renovate the facilities to meet current facility standards. In addition, the South 2nd Street facilities cannot be

made to meet post-9/11 requirements for protection of the workforce and mission.

ES-2.2 Need

NGA needs a new campus capable of supporting current and future mission requirements at a location that

complies with established standards for such facilities. Construction and operation of the campus needs to

meet the following site location and facility requirements:

1.

Allows for continuity and resiliency for existing and future NGA operations

2. Provides purpose-built facilities that are safe, secure, flexible, and efficient

3. Is conducive to recruiting and retaining top-quality employees

4. Stays within anticipated funding limits for construction, operation, and maintenance

5. Supports future changes to mission requirements

6. Provides necessary utilities, telecommunication, and transportation infrastructure

7. Contains a boundary that is a usable shape for necessary buildings and infrastructure and is outside a

100-year floodplain

8. Provides physical security and force protection with appropriate setbacks from adjacent roads,

railroads, and property boundaries

9.

Provides potential to use topography and landscape to enhance security

10. Site is available for acquisition and construction in early 2017

11. Meets or exceeds current building standards and codes, particularly those related to the design,

detailing, and construction of structural and non-structural components, to resist the effects of seismic

and other natural or human-made events

ES-3 Description of the Proposed Action

The NGA’s Proposed Action is to site, construct, and operate a purpose-built geospatial collection, analysis,

and distribution campus. The purpose-built facility will provide an open and flexible work environment that is

scalable, reconfigurable, and adaptive to changing mission requirements. The Next NGA West Campus would


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be designed to accommodate a workforce of approximately 3,150 government personnel and contractors.

Construction activities are expected to begin the summer of 2017 and last for approximately 5 years.

For the purpose of this EIS, a full build-out of the construction area is assumed, and no existing buildings or

infrastructure would remain. The following facilities would be constructed at the site:

Main operations building Data center (may be constructed sometime in the future)

Central utility plant

Visitor control center

Remote inspection facility

Primary and secondary access control points

Security fencing around the site perimeter

Supporting infrastructure, such as parking, interior roads, and sidewalks

ES-4 Description of the No Action Alternative

Under the No Action Alternative, the NGA would not construct or operate a new campus. NGA would remain

at the South 2nd Street location and these facilities would not be renovated or upgraded. Further, it is assumed

the current conditions at each of the proposed sites would continue. The No Action Alternative does not meet

the purpose and need of the Proposed Action. The No Action Alternative analysis serves as the baseline for

the comparison of environmental impacts.

ES-5 Alternatives Carried Forward for Analysis

Siting, construction, and operation of the Next NGA West Campus at one of four alternative locations

(Figure ES-1) are considered in the EIS. The alternative locations are described in detail in the following

subsections.

ES-5.1 Fenton Site

The Fenton Site (1050 Dodge Drive, Fenton, Missouri) is located in south St. Louis County, Missouri, on a

167-acre tract adjacent to Interstate 44/U.S. Route 50. This site is located within a larger 294-acre parcel

proposed for redevelopment as mixed-use build to suit industrial/commercial use along the Meramec River.

This property is the former location of a Chrysler automobile assembly plant that was demolished in 2009.

The existing site is flat and covered almost entirely in concrete and asphalt, which would be removed under

the Proposed Action. The property is unoccupied with the exception of a trailer used by the site developers as

a sales office. The Fenton Site is owned by a private developer and is currently for sale.


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Figure ES-1

Proposed Site LocaES-4


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ES-5.2 Mehlville Site

The Mehlville Site (13045 Tesson Ferry Road, St. Louis, Missouri) encompasses a 101-acre tract in south

St. Louis County, Missouri. The site is slightly graded with an existing 645,520-square-foot two-story office

complex with interconnected buildings constructed for Metropolitan Life Insurance Company in 1976. The

Mehlville property has a well-maintained office setting and grounds with parking, infrastructure, and interior

stormwater retention pond. Along the southern border of the Mehlville Site, the property contains natural

forested conditions. Because of NGA’s unique requirements, the existing office complex cannot be renovated.

The building, structures, and infrastructure would be removed as part of the Proposed Action. The Mehlville

Site is owned by private interests.

ES-5.3 St. Louis City Site

The St. Louis City Site (2300 Cass Avenue, St. Louis, Missouri) is a 100-acre site located within the city

limits of the city of St. Louis. This area is predominantly vacant land with some residential, light industrial,

and commercial use. It is situated just north of the city of St. Louis’ downtown at the intersection of Jefferson

and Cass Avenues. The city of St. Louis recommended this site for review because it is part of an ongoing

redevelopment effort by the city. Divestment has occurred over decades at the site, leading to a current

70 percent vacancy rate, and the city has designated the site a blighted community. A limited number of

community resources and homes remain within the proposed area footprint. Many of the vacant residential

lots are unmaintained and some have been converted into urban garden plots. The St. Louis City Site is within

the proposed NorthSide Regeneration Project area (NorthSide Regeneration St. Louis, 2015) and within the

U.S. Department of Housing and Urban Development’s footprint for an Urban Promise Zone initiative for the

city of St. Louis.

ES-5.4 St. Clair County Site

The St. Clair County Site (Wherry Road and Rieder Road) comprises 182 acres situated between Scott Air

Force Base (AFB) and MidAmerica St. Louis Airport near Shiloh, Illinois. This site is undeveloped and

relatively level, and approximately 80 percent of the location has been used as cultivated, agricultural land for

the past century. Scott AFB and its Cardinal Creek Golf Course bound the site to the south. The St. Clair

County Site is currently owned by St. Clair County.

ES-6 Public Outreach and Involvement

A variety of public involvement activities, tools, and techniques were used to engage community members

and government agencies during the EIS process, including a project website, formal public meetings,

informal stakeholder phone calls and meetings, elected and public official briefings, media briefings, mailed

announcements, emails, newspaper advertisements, and press releases. During NEPA scoping, NGA sought

input from government agencies, tribes, elected officials, non-governmental organizations, and the public on

the proposed construction and operation of a new campus. Input received during the scoping period assisted

NGA in identifying the concerns to focus on in the EIS. Public scoping meetings were held at the


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South 2nd Street facilities for NGA personnel and in community centers near each of the alternative sites for

the public. A detailed summary of the scoping meetings are presented in Appendix 1B NGA EIS Scoping

Report (Vector, 2015), and a full list of comments received along with government responses is provided in

Appendix 1C.

ES-7 Environmental JusticeEach alternative site location was assessed in consideration of Executive Order (E.O.) 12898 Federal Actionsto Address Environmental Justice in Minority Populations and Low-Income Populations. Section 5.0,

Environmental Justice, presents a description of the community around each site, along with the comparative

proportion of minority and low-income populations. USEPA's environmental justice screening and mapping

tool (EJSCREEN) and Census data were used to determine whether there are environmental justice concerns

present at each site.

The St. Louis City Site is the only site with substantial minority and low-income populations that may be

affected by the Next NGA West Campus, based on the EJSCREEN tool results and Census data. If the

St. Louis City Site is selected, the short-term impacts of relocation for residents and business would be borne

primarily by minority and low-income populations. However, this impact is not high and adverse in light of

the Missouri relocation statutes (Sections 523.200–215, RSMo, 2014), which also meet the requirements of

the federal Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended.

Additionally, the Next NGA West Campus is consistent with the city of St. Louis’ redevelopment plans for

the area and may provide a stabilizing effect, indirectly leading development attraction and eventual

momentum toward enhancing the NorthSide community resources.

E.O. 12898 calls for federal agencies to provide opportunities for stakeholders to obtain information and

provide comment on federal actions. NGA is complying with E.O. 12898 by conducting a public involvement

program that includes targeted efforts to engage, inform, and solicit input from minority and low-income

populations as demonstrated through additional meetings in the St. Louis City Site neighborhood and added

outreach to community leaders.

ES-8 Selection of Preferred Alternative

Council on Environmental Quality (CEQ) regulations at Title 40 of the Code of Federal Regulations (CFR)

Section 1502.14(e) require an agency to identify its preferred alternative, if one exists, in the Draft EIS. At

this time, NGA does not have a preferred alternative. However, NGA will identify the preferred alternative in

the FEIS.

ES-9 Approach to Environmental Analysis

The direct, indirect, and cumulative impacts of implementing NGA’s Proposed Action are evaluated in

accordance with the CEQ’s guidance for implementing NEPA (CEQ, 1983, 1997). The construction of the

proposed project would occur over a 5-year period and would include direct and indirect effects on the human


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and natural environments. Direct effects are caused by the action and occur at the same time and place,

whereas indirect effects are caused by the action, reasonably foreseeable, and occur later in time. Cumulative

impacts result from the incremental impact of the action when added to other past, present, and reasonably

foreseeable actions, which may be undertaken by other private or public entities. Fourteen natural and human

resource areas are analyzed in the EIS.

ES-10 Comparison of Environmental Impacts by Alternative

Table ES-1 presents the direct/indirect impacts, cumulative impacts, and the environmental protection

measures by resource area to illustrate the impact differences between the alternatives. Table ES-1

summarizes the areas where potential environmental impacts are present; impacts that were deemed

no/negligible in the analysis are not described in detail.


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ES-11 Summary of Findings by Site

Similar environmental impacts exist across the sites. For example, construction impacts such as use of

hazardous materials, noise generation and economic spending would be about the same regardless of the site

chosen. However, disparate impacts also exist between the sites: floodplains would be impacted only at the

Fenton Site, historic properties would be impacted only at the St. Louis City Site, and airspace would be

impacted only at the St. Clair County Site. The impacts associated with each site are briefly summarized in

the following subsections.

ES-11.1 Fenton Site

The land uses surrounding the Fenton Site are largely commercial and industrial, which are compatible with the

Proposed Action. No major negative environmental impacts would be expected from siting, constructing, and

operating the Next NGA West Campus at the Fenton Site.

Minor to moderate benefits may result from health and safety improvements, construction spending, induced

employment, land use improvements, cleanup of existing hazardous contamination, and the reduction of weed

species.

It is anticipated that the following minor to moderate, negative environmental impacts could occur if the Next

NGA West Campus is located at the Fenton Site:

Socioeconomics–Changing to federal ownership at this location would result in a loss of property tax

paid to the city of Fenton (approximately $5,502) and St. Louis County (approximately $462,308).

The city of St. Louis would lose approximately $2.19 million in City Total Earnings Tax through the

loss of tax from NGA non-residents of St. Louis.

Traffic and transportation–The surrounding road network would be affected during construction

periods only. There would likely be no transportation infrastructure failures as a result of the

increased traffic.

Noise–Noise from construction activities would be noticeable, but construction activities would

comply with state and local ordinances.

Hazardous material and solid waste–This site would generate approximately 1,198,730 cubic yards of

solid waste before re-use or recycling. This amount is approximately 0.56 percent of the total

permitted capacity of the three regional landfills that accept construction and demolition material.

Utilities–Site development would require upgrades to utility infrastructure and new connections,

including supply and service, potable water supply and services, wastewater and stormwater services,

and communications.

Water resources–No water resources or regulated waters would be impacted; however, construction

activities could occur within the 500-year floodplain. Any infrastructure located within the 500-year


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floodplain would be designed and constructed in compliance with all applicable federal guidelines

and regulatory requirements pertaining to floodplains.

Air quality and climate change–An increase in National Ambient Air Quality Standards (NAAQS)

criteria pollutant and carbon dioxide equivalents (CO2e) emissions would occur. However, emission

levels would be below regulatory thresholds.

Environmental protection measures, including standard best management practices (BMPs) as defined in

Table ES-1 and summarized at the end of each resource section, would need to be implemented to ensure

environmental impacts are maintained below defined thresholds.

ES-11.2 Mehlville Site

The land uses surrounding the Mehlville Site are largely commercial along Tesson Ferry Road, which is

compatible with the Proposed Action. No major benefits or negative environmental impacts would be expected

from siting, constructing, or operating the Next NGA West Campus at the Mehlville Site. Minor to moderate

benefits may result from construction spending, induced employment, surrounding land use improvements,

and cleanup of any existing contamination.

It is anticipated that minor to moderate, negative environmental impacts could occur to the following

resources:


paid to St. Louis County (approximately $545,495). The city of St. Louis would lose approximately

$2.19 million in City Total Earnings Tax through the loss of tax from NGA non-residents of St.

Louis.

Traffic and transportation–There would be an impact to the roadway network at the entrance to the

Next NGA West Campus, along Tesson Ferry Road. NGA would work with MoDOT to install a

traffic signal to alleviate this concern.

Noise–Noise from construction activities would be noticeable, but construction would comply with

state and local ordinances.

Hazardous material and solid waste–This site would generate approximately 116,920 cubic yards of




including supply and service, potable water supply and services, wastewater and stormwater services,

and communications.


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Water resources–A single, forested wetland, approximately


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Following the analysis performed for the St. Louis City site, it is anticipated that other minor to moderate

negative environmental impacts could occur to the following resources:


paid to the city of St. Louis (approximately $64,180), but the City would retain the City Total

Earnings Tax from NGA personnel.

Land Use–The city of St. Louis is working on agreements with local community members for

property purchases and relocations. All relocations and displacements would occur in compliance

with the Missouri relocation statutes, which require fair compensation for relocated individuals.

Health and safety–Road realignments could result in a minor impact to emergency response times in

the area.

Traffic and transportation–There would be an impact to the roadway network at the two entrances to

the NGA campus without signals, which are located along Jefferson Avenue and Cass Avenue. NGA

would coordinate with MoDOT to install actuated traffic signals to alleviate this issue.

Noise–Noise during construction would be noticeable to nearby residences and businesses.

Hazardous material and solid waste–This site would generate approximately 85,650 cubic yards of



Biology–Migratory birds could be affected by the Proposed Action during construction.


including power supply and service, potable water supply and services, wastewater and stormwater

services, and communications.

Air quality and climate change–An increase in NAAQS criteria pollutant and CO2e emissions would

occur. However, emission levels would be below regulatory thresholds.

Standard BMPs, as defined in Table ES-1 and summarized at the end of each resource section, would need to

be implemented to ensure environmental impacts are maintained below defined thresholds.

ES-11.4 St. Clair County Site

St. Clair County offered the St. Clair County Site as an option to be evaluated for the EIS. To accommodate

the NGA proposal, a county zoning restriction of building heights has been lifted to allow for campus

construction at this location. No major environmental benefits are associated with this site; however, there is a

potential major negative impact.

A previously identified archaeological site listed on the NRHP is located within the footprint of the St. Clair

County Site. Because of the potential impacts to this archeological site, NGA, USACE, and St. Clair County


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are currently reaching out to the Illinois State Historic Preservation Office and local interest groups to

determine the appropriate mitigation for impacts to this resource.

Minor to moderate benefits may result from the reduction of potential noxious weeds on the site, health and

safety improvements, land use improvements.

Following the analysis performed for the St. Clair County site, it is anticipated that minor to moderate,negative environmental impacts could occur to the following resources:

Socioeconomics–The city of St. Louis would lose approximately $2.19 million in City Total Earnings

Tax through the loss of tax from NGA non-residents of St. Louis. There would be no change to the

County’s property tax revenue; the site is already exempt from property taxes because it is

County-owned. However, St. Clair County would no longer receive the income associated with

current agricultural leases.

Traffic and transportation–There would be an impact to the St. Clair County Site roadway network at

the signalized intersection of Route 158 at Wherry Road. NGA would coordinate with IDOT to add

an exclusive right turn lane to westbound Wherry Road to alleviate this issue.


including power supply and service, potable water supply and services, wastewater and stormwater

services, and communications.

Water resources–A single, forested wetland, approximately 2.1 acres in size, is located in the

southwestern part of the site. Under the Proposed Action, construction activities would most likely

displace the wetland on the site. Other surface waters include a 2,092-linear-foot perennial stream, an

intermittent stream, and a 0.9-acre pond. Impacts to the surface waterbodies that qualify as waters of

the United States from the proposed infrastructure construction would require a CWA Section 404

permit from USACE, St. Louis District and Section 401 Water Quality Certification from IEPA.

Biological resources–Site development would impact present wildlife and vegetation.

Air quality and climate change–It is anticipated that an average roundtrip commute would increase

from 26.4 miles to 58.2 miles based on current workforce zip codes. Despite the increase in commute

distance, the annual operational emissions would be less than the federal de minimis thresholds for

criteria pollutants and the 25,000-metric ton reporting threshold for CO2e.

Airspace–Because of the proximity to Scott AFB, NGA would coordinate with the FAA to perform an

aeronautical study under 14 CFR 77 to determine the potential impacts to flight patterns and operations

within the existing airspace. There should be minimal change to flight patterns if this site is selected.

Standard BMPs, as defined in Table ES-1 and summarized at the end of each resource section, would need to

be implemented to ensure environmental impacts are maintained below defined thresholds.

Documents

Next NGA West Draft EIS, St. Louis - Executive Summary