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An Environmental Assessment (EA) for the proposed temporary facilities for sheltering unaccompanied children at Goodfellow Air Force Base (AFB), Texas. The EA analyzes the potential environmental consequences of the erection and operation of these facilities by the U.S. Department of Health and Human Services (HHS) and provides environmental protection measures to minimize adverse impacts. The document also discusses the impact on Goodfellow AFB commercial traffic, hazardous materials and wastes, cultural resources, and other stakeholders.
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Pursuant to provisions of the National Environmental Policy Act (NEPA), Title 42 United States Code (U.S.C.) Sections 4321 to 4347, implemented by Council on Environmental Quality (CEQ) Regulations, Title 40, Code of Federal Regulations (CFR) §§1500-1508, and 32 CFR §989, Environmental Impact Analysis Process, the U.S. Air Force (Air Force) assessed the potential environmental consequences associated with The U.S. Department of Health and Human Services (HHS) Temporary Facilities for Sheltering Unaccompanied Children at Goodfellow Air Force Base (AFB), Tom Green County, Texas.
The purpose of the Proposed Action is to support the urgent HHS requirement, as documented in a Request for Assistance, for providing temporary shelter by using available military resources, as directed by the Secretary of Defense and documented in an Action Memorandum (29 June 2018).
The need for the Proposed Action is to respond to a humanitarian crisis resulting from the increased influx of unaccompanied children across the southern border of the United States. The current influx of unaccompanied children along the U.S. southern border continues to strain HHS’s usual system of caring for unaccompanied children.
The Environmental Assessment (EA) analyzes the potential environmental consequences of activities associated with the erection by Air Force and operation by HHS of temporary facilities for sheltering unaccompanied children at Goodfellow AFB, and provides environmental protection measures to avoid or reduce adverse environmental impacts.
The EA considers all potential impacts of Alternative 1 and the No Action Alternative. The EA also considers cumulative environmental impacts with other projects in the Region of Influence.
Alternative 1: Proposed Action (Preferred Alternative)
Under the Proposed Action, the Air Force would provide approximately 70 contiguous acres of level and cleared land, erect temporary structures to provide living and sleeping quarters for up to 7, unaccompanied children and work facilities for approximately 7,500 HHS support staff for up to 180 days. The Proposed Action would provide sufficient support structures, construction laydown area, and security fencing to separate the temporary facilities from other areas and functions at Goodfellow AFB, Texas. The Proposed Action would include providing all care, supervision, meals, clothing, medical services, transportation, and other daily needs of the unaccompanied children.
The following activities would be completed by the Air Force to enhance unaccompanied children capacity in a timely manner:
Clearing and leveling land for the purpose of erecting semi-permanent structures to shelter unaccompanied children; Allowing HHS to use the Department of Defense’s temporary facilities for mass sheltering; Erecting temporary facilities; and Helping transport unaccompanied children from one facility to another in the event of a significant weather event or natural disaster.
shelters at Goodfellow AFB to support HHS operations, HHS would not operate the facilities, and would not meet the requirements of the Presidential Executive Order 13841 and Secretary of Defense Action Memorandum (29 June 2018). All alternative strategies, including the No Action Alternative, will be assessed in the EA.
SUMMARY OF FINDINGS
The analyses of the affected environment and environmental consequences of implementing the Preferred Alternative presented in the EA concluded that by implementing standing environmental protection measures and operational planning, the Air Force would be in compliance with all items and conditions and reporting requirements.
The Air Force has concluded that no significant adverse impacts would result to the following resources as a result of the Preferred Alternative: airspace management, water resources, noise, land use, air quality, biological resources, cultural resources, earth resources, hazardous materials and wastes, infrastructure and utilities, transportation, socioeconomic resources, environmental justice, and safety and occupational health. No significant adverse cumulative impacts would result from activities associated with Preferred Alternative when considered with past, present, or reasonably foreseeable future projects.
FINDING OF NO SIGNIFICANT IMPACT BY THE AIR FORCE
Based on my review of the facts and analyses contained in the attached EA, conducted under the provisions of NEPA, CEQ Regulations, and 32 CFR §989, I conclude that the Air Force portion of the Preferred Alternative would not have a significant environmental impact, either by itself or cumulatively with other known projects. Accordingly, an Environmental Impact Statement is not required. The signing of this Finding of No Significant Impact completes the environmental impact analysis process.
CYNTHIA OLIVA, GS-15, USAF Date Chief, Resource Integration Division
Cover Sheet
Responsible Agency: 17th Training Wing, Goodfellow Air Force Base (AFB), Texas
Proposed Action: The U.S. Department of Health and Human Services (HHS) Temporary Facilities for Sheltering Unaccompanied Children at Goodfellow AFB, Texas
Points of Contact:
Air Force: Erika Alanis Unger, 17 CES/CEIE, 460 Kearney Blvd, Goodfellow AFB, Texas 76908
HHS: Commander Gregg Gnipp, U.S. Public Health Service, Division of Unaccompanied Children Planning & Logistics Administration for Children & Families, Switzer Building, 330 C St SW, Office 5208C, Washington, DC 20024
Report Designation: Draft Environmental Assessment (EA)
Abstract: To address an increased influx of unaccompanied children across the southwestern border of the United States, Goodfellow AFB is preparing an EA addressing potential environmental impacts from the HHS temporary facilities for sheltering unaccompanied children. The environmental impact analysis process for this EA is being conducted in accordance with the Council on Environmental Quality regulations pursuant to the requirements of the National Environmental Policy Act (NEPA) of 1969.
Under the Proposed Action, the Air Force would provide approximately 70 contiguous acres of level and cleared land, erect temporary structures to provide living and sleeping quarters for up to 7, unaccompanied children and work facilities for approximately 7,500 HHS support staff for up to 180 days. The Proposed Action would provide sufficient support structures for HHS operation of the facilities, construction laydown area, and security fencing to separate the temporary facilities from other areas and functions at Goodfellow AFB, Texas. HHS would operate the proposed facilities under the Proposed Action.
As required by NEPA, the Air Force will also consider taking no action (No Action Alternative). By taking no action, the Air Force would not provide temporary, short-term shelters at Goodfellow AFB to support HHS operations, HHS would not operate the facilities, and would not meet the requirements of the Presidential Executive Order 13841 and Secretary of Defense Action Memo (29 June 2018). All alternative strategies, including the No Action Alternative, will be assessed in the EA.
The following resources were identified for study in this EA: noise, land use, air quality, biological resources, cultural resources, earth resources, hazardous materials and wastes, infrastructure and utilities, transportation, socioeconomic resources, environmental justice, and safety and occupational health.
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Table 3-5. Employment by Industry ........................................................................................................ 3-
Table 3-6. Hotel Data within 90 Mile Radius of Goodfellow AFB ......................................................... 3-
Table 3-7. Low Income, Minority, Child, and Elderly Populations in the ROI ....................................... 3-
Table 4-1. Construction Equipment Peak SPLs ......................................................................................... 4-
Table 4-2. Results of ACAM Assessment ................................................................................................. 4-
Table 4-3. Percent Minority and Low Income in the ROI as Compared to the COC .............................. 4-
Table 5-1. Past, Present, and Reasonably Foreseeable Future Actions...................................................... 5-
Figure Page
Figure 1-1. Regional Location of Goodfellow AFB .................................................................................. 1-
Figure 2-1. Proposed Action Area ............................................................................................................. 2-
Figure 2-2. Proposed Action Area and Alternatives .................................................................................. 2-
Figure 3-1. Maximum Sound Level (Lmax) and Sound Exposure Levels (SEL) Comparison ................. 3-
Figure 3-2. Land Use at the Proposed Action Area ................................................................................... 3-
Figure 3-3. ERP and AOC at Proposed Action Area ............................................................................... 3-
Figure 3-5. Utilities at the Proposed Action Area .................................................................................... 3-
Appendix A Interagency/Intergovernmental Coordination, Consultations, and Public Notifications
Appendix B Air Quality Assessment
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ACAM Air Conformity Applicability Model ACM Asbestos-Containing Materials AEP American Electrical Power AFI Air Force Instruction AFB Air Force Base AIRFA American Indian Religious Freedom Act Air Force United States Air Force AOC Area of Concern APE Area of Potential Effect ARPA Archaeological Resources Protection Act AQCR Air Quality Control Region bgs Below ground surface BMPs Best Management Practices CAA Clean Air Act CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CEQ Council on Environmental Quality CFR Code of Federal Regulations CH 4 Methane CO Carbon Monoxide CO 2 Carbon Dioxide CO 2 eq Carbon Dioxide Equivalent COC Community of Comparison dB Decibel dBA A-weighted Decibel DHS Department of Homeland Security DoD Department of Defense DoJ Department of Justice EA Environmental Assessment EIAP Environmental Impact Analysis Process EIS Environmental Impact Statement EO Executive Order ERP Environmental Restoration Program ESA Endangered Species Act ESQD Explosive Safety Quantity Distance FM Farm-to-Market Road FONPA Finding of No Practicable Alternative FONSI Finding of No Significant Impact FPPA Farmland Policy Protection Act ft Feet FY Fiscal Year GHGs Greenhouse Gasses HAPs Hazardous Air Pollutants HFCs Hydrofluorocarbons HHS Department of Health and Human Services IDP Installation Development Plan IICEP Interagency and Intergovernmental Coordination for Environmental Planning INRMP Integrated Natural Resources Management Plan IPaC Information, Planning and Conservation
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CHAPTER 1: PURPOSE OF AND NEED FOR THE PROPOSED ACTION
1.1 INTRODUCTION
On 20 June 2018 President Trump signed Executive Order (EO) 13841 establishing a policy to “rigorously enforce our immigration laws”. The EO further directed the Secretary of Defense to “take all legally available measures to provide the Secretary [of Homeland Security], upon request, any existing facilities available for the housing and care of alien families, and shall construct such facilities if necessary”. According to Presidential Memorandum dated 6 April 2018, the Department of Homeland Security (DHS), in coordination with the Department of Defense (DoD), the Department of Justice (DoJ), and the Department of Health and Human Services (HHS), was to “report existing facilities that could be used, modified, or repurposed to detain aliens”. By letter dated 19 June 2018, the HHS requested “further cooperation and support from the DoD to mitigate the crisis of unaccompanied alien children arriving at the Southern Border.”
To address an increased influx of unaccompanied children across the southwestern border of the United States, DHS developed a Programmatic Environmental Assessment (PEA) (DHS 2014). The DHS assessed a general approach for managing processing of unaccompanied children and transferring their care to HHS during the present humanitarian situation. Subsequent to HHS request, the U.S. Air Force (Air Force) determined Goodfellow Air Force Base (AFB), Texas could enhance sheltering capacity necessary to accommodate the unaccompanied children.
Goodfellow AFB is home to the 17th^ Training Wing. Encompassing 1,214 acres, Goodfellow AFB is located within the southeast corner of the City of San Angelo, Texas in Tom Green County, as shown in Figure 1-1. The Mission at Goodfellow AFB is to train, develop, and inspire exceptional intelligence, surveillance, and reconnaissance and fire protection professionals for America and her allies.
The 1969 National Environmental Policy Act (NEPA), as amended, requires federal agencies to consider environmental consequences in their decision-making process. The President’s Council on Environmental Quality (CEQ) has issued regulations to implement NEPA that include provisions for both the content and procedural aspects of the required environmental impact analysis. The Air Force Environmental Impact Analysis Process (EIAP) is accomplished through adherence to the procedures set forth in CEQ regulations (40 Code of Federal Regulations [CFR] §§1500-1508) and 32 CFR §989 ( Air Force Environmental Impact Analysis Process ). These federal regulations establish both the administrative process and substantive scope of the environmental impact evaluation designed to ensure that deciding authorities have a proper understanding of the potential environmental consequences of a contemplated course of action.
The information presented in this document will serve as the basis for deciding whether the Proposed Action would result in a significant impact to the human environment, requiring the preparation of an environmental impact statement (EIS), or whether no significant impacts would occur, in which case a finding of no significant impact (FONSI) would be appropriate_._
1.2 DESCRIPTION OF THE PROPOSED ACTION AND LOCATION
The Proposed Action would provide HHS sufficient land and facilities for the placement of living and sleeping quarters for approximately 7,500 unaccompanied children on Goodfellow AFB, with additional work space for approximately 7,500 HHS support personnel. HHS identified the following activities that would be necessary to enhance capacity in a timely manner and to avoid elevated costs:
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Clearing and leveling land for the purpose of erecting semi-permanent structures to shelter unaccompanied children; Allowing HHS to use DoD’s temporary facilities for mass sheltering; Erecting temporary facilities; and Helping transport unaccompanied children from one facility to another in the event of a significant weather event or natural disaster.
The Air Force, as requested by HHS, would provide the required land, temporary facilities and other support at Goodfellow AFB, Texas. HHS representatives would be present on-site and would provide all care, supervision, meals, clothing, medical services, transportation, and other daily needs of the unaccompanied children. HHS has requested the facilities be available for 180 days from the arrival of the first unaccompanied children. The HHS timeframe noted in the Notice of Availability (NOA) and public notices was established based upon planning assumptions known at the time of publication. Based on clarifications, the current planning assumptions for the timeframe of the Proposed Action would be 180 days from the arrival of the first unaccompanied children. All resource areas are analyzed for impacts over a 180-day timeframe. HHS has not projected a timeframe for the arrival of the unaccompanied children, up to the maximum of 7,500 total. It is expected the children and HHS staff will arrive onsite in stages. For the purpose of the analysis, the buildup is estimated to be 1,000 unaccompanied children and 1,000 HHS staff per week. So, the buildup would be over a 7.5 week period, if full capacity is reached.
1.3 PURPOSE OF AND NEED FOR THE PROPOSED ACTION
The CEQ regulations implementing the NEPA require that an Environmental Assessment (EA) specify the underlying purpose of and need to which an agency is responding in proposing actions and alternatives (40 CFR 1502.13).
The purpose of the Proposed Action is to support the urgent HHS requirement, as documented in a Request for Assistance, for providing temporary shelter by using available military resources, as directed by the Secretary of Defense and documented in an Action Memorandum (29 June 2018). Specifically, the purpose of the Proposed Action is to establish and operate a location and erect temporary, short-term facilities for sheltering approximately 7,500 unaccompanied children at Goodfellow AFB.
The need for the Proposed Action is to respond to a humanitarian crisis resulting from the increased influx of unaccompanied children across the southern border of the United States. The current influx of unaccompanied children along the U.S. southern border continues to strain HHS’s usual system of caring for unaccompanied children.
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Goodfellow AFB, Texas
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1.4 DECISION TO BE MADE
The analysis in this EA evaluates the potential environmental consequences of the proposed and alternative actions. Based on this information, the Air Force would determine whether to implement the Proposed Action or take no action (No Action Alternative). HHS would determine whether to implement its portion of the Proposed Action or take no action. As required by NEPA and its implementing regulations, preparation of an environmental document must precede final decisions regarding the proposed action, and be available to inform decision-makers of the potential environmental impacts of selecting the Proposed Action or the No Action Alternative. If significant impacts are identified, the Air Force or HHS would undertake mitigation to reduce impacts to below the level of significance, undertake the preparation of an EIS addressing the Proposed Action, or abandon the Proposed Action.
1.5 APPLICABLE REGULATORY REQUIREMENTS AND INTERGOVERNMENTAL
COORDINATION
The following paragraphs describe the laws and regulations that apply, or may apply, to the Proposed Action, as well as the different levels of consultation required by federal law.
HHS is a cooperating agency because they will operate the facilities.
The Air Force, as the responsible agency has implemented the Interagency and Intergovernmental Coordination for Environmental Planning (IICEP) process. Through the IICEP process, the Air Force notifies relevant federal, state, and local agencies about the Proposed Action and alternatives. The IICEP process provides the Air Force the opportunity to coordinate with and consider state and local views in implementing the Proposed Action or alternatives. A discussion of the Proposed Action was provided to federal, state, and local agencies as well as other stakeholders identified in the IICEP process that provides the means to comment on the Proposed Action and alternatives. The comment period lasts for 7 days. Agency responses were considered in developing the final EA. IICEP materials for this EA are included in Appendix A.
The National Historic Preservation Act (NHPA) requires federal agencies to consult with federally recognized Indian tribes on proposed undertaking that have the potential to affect Properties of cultural, historical, or religious significance to the tribes. Because many tribes were displaced from their original homelands during the historical period, tribes with cultural roots in an area might not currently reside in the region where the undertaking is to occur. Effective consultation requires identification of tribes based on ethnographic and historical data and not simply a tribe’s current proximity to a project area. The goal of the tribal consultation process is not to simply consult on a particular undertaking but rather to build constructive relationships with appropriate Native American tribes.
On 3 July 2018, the 17th^ Training Wing Commander at Goodfellow AFB sent letters to the tribes culturally affiliated with the installation, requesting government-to-government consultation to identify any traditional cultural properties that may be present. These letters, and any responses received, are included in Appendix A.
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CHAPTER 2: DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES
This section provides detailed information on the Proposed Action and the No Action Alternative. As discussed in Section 1.4 , the NEPA process evaluates potential environmental consequences associated with a Proposed Action and considers alternative courses of action. Reasonable alternatives must satisfy the purpose of and need for a Proposed Action, as defined in Section 1.3. In addition, CEQ regulations also specify the inclusion of a No Action Alternative against which potential effects can be compared. While the No Action Alternative would not satisfy the purpose of or need for the Proposed Action, it is analyzed in accordance with CEQ regulations.
HHS recently conducted site visits at the following Air Force installations: Goodfellow AFB, Texas, Dyess AFB, Texas and Little Rock AFB, Arkansas. The sites were evaluated for HHS requirements, including:
Available for occupancy within 30 days of formal notification from the Administration for Children and Families Available for at least six months Able to be fenced or have adequate security Space for a minimum of 7,500 beds Separated from military activity Within 100 miles of an airport serviced by major air carriers Within 100 miles of a major city
After careful consideration, it was determined that Goodfellow AFB met all the required criteria for the Proposed Action by HHS. Dyess AFB and Little Rock AFB are not suitable by HHS based on the above criteria. Dyess AFB does not have availability for occupancy within 30 days due to lack of infrastructure and time needed to prepare the site. Little Rock AFB available siting locations are within close proximity to residential housing and would not have adequate security.
2.1 SELECTION STANDARDS FOR LOCATIONS ON GOODFELLOW AFB
Goodfellow AFB developed the Proposed Action and reasonable alternatives carried forward for analysis by weighing all possible courses of action capable of meeting the Purpose and Need against the following selection standards. These selection standards are based upon HHS needs with respect to providing temporary, short-term shelters for unaccompanied children, and are listed below:
Site at least 25 acres in size Staging area for service trailers Outside space available for wrap-around services Road access to the site Ability to tie to existing utilities Removed from military activity
2.2 DESCRIPTION AND SCREENING OF ALTERNATIVES
NEPA and the CEQ regulations mandate the consideration of reasonable alternatives for the Proposed Action. Reasonable alternatives are those that could be used to meet the purpose of and need for the Proposed Action. The following alternatives were identified and screened against the selection standards.
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Under the Proposed Action, the Air Force would provide approximately 70 contiguous acres of level, cleared land, and erect temporary structures to provide living and sleeping quarters for up to 7, unaccompanied children and work facilities for approximately 7,500 HHS support staff for up to 180 days. The Proposed Action would provide sufficient support structures, construction laydown area, and security fencing to separate the temporary facilities from other areas and functions at Goodfellow AFB.
The following activities would be necessary to enhance unaccompanied children capacity in a timely manner:
Clearing and leveling land for the purpose of erecting semi-permanent structures to shelter unaccompanied children; Allowing HHS to use DoD’s temporary facilities for mass sheltering; Erecting temporary facilities; and Helping transport unaccompanied children from one facility to another in the event of a significant weather event or natural disaster.
Figure 2-1 provides the location of the Proposed Action area on Goodfellow AFB, the available site meeting all of the selection standards.
