USCG Station Tybee NEPA EA_DRAFT PUBLIC REVIEW 12222020 REV1.pdf

USCG STATION TYBEE REBUILD PROJECT ON COCKSPUR ISLAND GEORGIA

DRAFT ENVIRONMENTAL ASSESSMENT

The U.S. Coast Guard (USCG) Draft Environmental Assessment (DEA) was prepared in accordance with Environmental Planning Policy, COMDTINST 5090.1 (series) and is in compliance with the National Environmental Policy Act of 1969 (42 U.S.C. Sections 4321 to 4370h)) and the Council of Environmental Quality Regulations 14 September 2020 (40 Code of Federal Regulations [CFR] Parts 1500-1508).

This DEA serves as a concise public document to briefly provide sufficient evidence and analysis for determining the need to prepare an Environmental Impact Statement (EIS) or a Finding of No Significant Impact (FONSI). This DEA concisely describes the Proposed Action, the need for the proposal, the alternatives, and the environmental impacts of the proposal and alternatives. This DEA also contains a comparative analysis of the action and alternatives, a statement of the environmental significance of the preferred alternative, and a list of the agencies and persons consulted during DEA preparation.

Environmental Engineer Level II Title/Position NEPA Warrant

Richard D. Hylton. P.E.

Document Preparer

I reviewed the EA and submitted my written comments to the Proponent.

Environmental Protection Specialist Level II Title/Position NEPA Warrant

Lesley Dobbins-Noble Environmental Reviewer

I reviewed the EA and submitted my written comments to the Proponent.

Environmental Protection Specialist Level III Title/Position NEPA Warrant

Dean Amundson Senior Environmental Professional

In reaching my decision/recommendation on the Coast Guard’ Proposed Action, I considered the information contained in this DEA and considered and acknowledge the written comments submitted to me from the Environmental Reviewer(s).

Commanding Officer – Facilities Design & Construction Center Title/Position

Captain J.F. Barresi Proponent

HYLTON.RICHARD

.D.JR.1229466069

Digitally signed by

HYLTON.RICHARD.D.JR.122946

Date: 2020.12.22 10:47:52 -05'00'

DOBBINS-

NOBLE.LESLEY.CA

ROLE.1047416848

Digitally signed by DOBBINS-

NOBLE.LESLEY.CAROLE.10474

16848 Date: 2020.12.22 11:03:30 -05'00'

Digitally signed by

AMUNDSON.DEAN.JAY.127401

Date: 2020.12.28 10:09:46 -08'00'

Digitally signed by

BARRESI.JOHN.F.JRII.1187016629

Date: 2021.01.04 09:19:41 -05'00'

U.S. Department of Homeland Security

United States Coast Guard

United States Coast Guard

DRAFT Environmental Assessment for the USCG

Station Tybee Station Rebuild Project

Cockspur Island, Chatham County, Georgia

Contract Number 70Z05019DARCADI01

Task Order Number 70Z05020FSTATYB00

December 2020

Draft Environmental Assessment December 2020

USCG Station Tybee Station Rebuild Project i

EXECUTIVE SUMMARY

ES 1. Introduction

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

Policy Act (NEPA) of 1969, as amended (Public Law 91-190, 42 United States Code [U.S.C.] §4321 et.

seq.); the Council on Environmental Quality (CEQ) Regulations Implementing the Procedural Provisions of

NEPA (40 Code of Federal Regulations [CFR] §§1500-1508); Department of Homeland Security (DHS)

Management Directive 023-01-001-01 (series) Implementation of the National Environmental Policy Act;

and United States Coast Guard (USCG) Commandant Instruction (COMDTINST) 5090.1 (series), U.S.

Coast Guard Environmental Planning Policy; and the National Park Service (NPS) Director’s Order 12.

This EA evaluates the environmental impacts of the USCG’s proposal to rebuild hurricane-damaged facilities at USCG Station Tybee (the Station; Proposed Action) and its alternatives. The information and analysis contained within this EA will determine whether implementation of the Proposed Action would have a significant impact on the environment, requiring preparation of an Environmental Impact Statement

(EIS). If no significant impacts would occur, a Finding of No Significant Impact (FONSI) would be appropriate.

ES.2 Scope of the Environmental Assessment

This EA evaluates the potential environmental impacts of implementing the Proposed Action and reasonable alternatives. In accordance with NEPA and CEQ regulations, this EA considers two action alternatives – Rebuild Option 1 and Rebuild Option 2 (the Preferred Action Alternative) – for implementing the Proposed Action. The No Action Alternative is also evaluated as required by CEQ regulations and

COMDTINST 5090.1. Full descriptions of the two rebuild alternatives and No Action Alternative are provided in Section 2.2.

ES. 3 Background

The USCG has prepared this EA to evaluate the potential environmental impacts from constructing a new

Multi-Mission Station Facility (hereafter referred to as the Multi-Mission Building [MMB]), demolishing selected existing onshore facilities, and all associated site work including repair of the riprap along the shoreline of Station Tybee. Collectively, these activities constitute the Proposed Action evaluated in this

EA. Construction of the MMB would replace multiple onshore buildings at Station Tybee that were substantially damaged during Hurricane Matthew in 2016, including the Station Building. The EA will also allow the NPS to determine if the improvements included in the Proposed Action are appropriate for Fort

Pulaski National Monument (referred to by the NPS as the Park Area) and consistent with the Park Area’s

General Management Plan and other applicable laws. Review and approval by the NPS of proposed improvements is subject to compliance with NEPA.

ES. 4 Purpose and Need

The purpose of the Proposed Action is to accomplish the Station’s various missions by rebuilding the

Station to replace storm-damaged and aging facilities. Implementation of the Proposed Action would equip the Station with modern facilities that comply with today’s standards and harden its infrastructure for future resiliency.

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The Proposed Action is needed to: (1) replace aging facilities that no longer meet Coast Guard needs; (2) repair damages to facilities, such as the rip-rap along the shoreline, incurred from Hurricane Matthew and prior storm events; and (3) provide resilient facilities to support mission execution, especially during future storm events. Addressing these elements will create a Station that fulfills the needs and requirements of the units that use it. Additionally, it will remedy the issues and constraints that the units have experienced as a result of aging and damaged facilities, while also hardening the Station’s infrastructure for future resiliency.

ES.5 Proposed Action and Alternatives

The USCG’s Proposed Action consists of the following primary components:

1) At the Station Tybee compound, construct and operate a new 26,000 gross square foot (GSF) MMB;

repair the stone riprap along the Station shoreline; complete major site work to include reconfiguring parking areas and internal Station roads; and make major upgrades to utilities.

2) Demolish existing facilities at Station Tybee that do not meet USCG and resiliency requirements and remove temporary office trailers at the Station following completion of the proposed MMB.

3) Upgrade/replace the existing wastewater treatment system currently operated by the NPS in an area

(Area A), located to the immediate southeast of the Station Tybee compound, with the USCG to complete the upgrade/replacement and then maintain the upgraded system under an Inter-Agency

Agreement (IAA) with the NPS.

4) Upgrade the existing NPS boat ramp, including adding a floating dock, to accommodate USCG boats in an area (Area B) to the east of the Station Tybee compound, with the USCG to complete the improvements and use the boat ramp and NPS to have administrative use of the area per the IAA.

5) Upgrade the existing potable water supply groundwater well system, including constructing a new pump house in an area (Area C) to the far southeast of the Station Tybee compound, with the USCG making the improvements for shared use by the USCG and NPS, and the NPS maintaining all upgrades and improvements in the future per the IAA.

ES.5.1 Action Alternatives

Each of the two action alternatives, described below, would include waterfront and shore infrastructure upgrades and/or replacements.

Alternative 1: Rebuild Option 1

Alternative 1 would demolish Station Building 101 (15,857 GSF) and support buildings, including Buildings

102, 109, and other buildings (total 23,096 GSF), and replace them with an MMB designed and built to modern standards. Construction of a total of 26,000 GSF, which would account for replacing Building

101, adding boat storage, and replacing Buildings 102, 109, and the Aids to Navigation Team (ANT

Tybee) Building 115, would satisfy the facility requirements for Station Tybee, ANT Tybee, and Coast

Guard Cutter (CGC) POMPANO functions combined. The USCG would improve the existing wastewater treatment system, if feasible, within the Station and realign parking and roads within the compound.

Alternative 1 also includes major erosion repairs to the existing stone riprap along the shoreline of the

Savannah River at Station Tybee. A new boat ramp would be constructed within the Savanah River to the east of the existing Station pier.

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The new MMB building, to replace Building 101 and other buildings, would be re-constructed to the west of the current location of Building 101, and the main entrance gate would be shifted to the west to provide space for circulation and parking for trailered boats and shop operations. This would also include some associated pavement expansion and utilities extension.

During the construction period (estimated at 18 to 24 months), temporary space would be provided in trailers on site and off site. With this alternative, Station Tybee would continue to use the existing land parcel; however, it would not use the NPS boat ramp or wastewater treatment system, which are beyond the Station compound boundaries and owned and operated by the NPS.

Alternative 2: Rebuild Option 2 (Preferred Alternative)

Alternative 2 (the Preferred Alternative) would demolish Station Building 101 (15,857 GSF) and support buildings, including Buildings 102, 109, 115, and other buildings (total 23,096 GSF), and replace them with an MMB designed and built to modern standards. Construction of a total of 26,000 GSF (replacing

Building 101; adding boat storage; and replacing Buildings 102, 109, and ANT Tybee Building 115) would satisfy the facility requirements for Station Tybee, ANT Tybee, and CGC Pompano functions combined.

In contrast to Alternative 1, Alternative 2 would:

Upgrade/replace the existing wastewater treatment system currently operated by the NPS in an area

(Area A) located to the immediate southeast of the Station Tybee compound;

Upgrade an existing NPS boat ramp to accommodate USCG boats in an area (Area B) to the east of

Station Tybee; and

Upgrade the existing potable water supply groundwater well system, including constructing a new pump house (Area C) and upgrading the existing gravel parking lot at the NPS picnic pavilion and the access drive thereto (Area C).

Under the terms of the IAA, the USCG will upgrade the wastewater treatment system and use and maintain it and will upgrade and use the NPS boat ramp. The USCG will complete the improvements to the existing water supply system in Area C, and the NPS will operate and maintain them.

ES.5.2 No Action Alternative

The No Action Alternative would retain existing facilities (buildings and piers) for indefinite continued use with only routine repair and maintenance provided. No additional space would be constructed, and no major building renovation/repair would be performed. Although Station Building 101 requires significant structural repairs to extend its useful life, the cost of major renovation/repair of the building would well exceed 50 percent of its Plant Replacement Value, and the USCG previously determined that it is not cost-effective to attempt major renovation of this building; therefore, the No Action Alternative is deemed non-viable, as it does not meet the Purpose and Need.

ES.6 Agency Consultations and Public Involvement

Pursuant to the requirements of NEPA (40 CFR 1506.6), this EA is subject to public involvement.

Agencies, organizations, and members of the public with a potential interest in the Proposed Action were invited and encouraged to participate. The USCG will publish and distribute the Draft EA for a 30-day public review and comment period, which will be announced by a Notice of Availability published in the

Savannah Morning News and Savannah Tribune. Substantive comments received on the Draft EA during iv this 30-day review period will be addressed in the Final EA. Interagency and intergovernmental coordination is a federally mandated process for informing and coordinating with other governmental agencies regarding federal proposed actions. CEQ regulations require intergovernmental notifications before making any detailed statement of environmental impacts. A complete list of federal, state, and local agencies consulted for this EA is included in Section 7.0, and copies of relevant correspondence with those agencies are provided in Appendices A and B. Information and comments received from these agencies have been incorporated into this EA as appropriate. Native American tribes were also invited to participate in the NEPA and National Historic Preservation Act (NHPA) Section 106 processes in accordance with Executive Order (EO) 13175, Consultation and Coordination with Indian Tribal

Governments. Copies of relevant correspondence to and from the GA SHPO under Section 106 of the

NHPA and tribal correspondence are provided in Appendix B.

A summary of the environmental impacts of each alternative is provided in Table ES-1. The analysis assumes that best management practices (BMPs) included as standard provisions of USCG contracts and developed during federal planning processes would be employed to avoid or minimize significant adverse impacts on the environment. Implementing BMPs would ensure that the Proposed Action would avoid significant impacts or reduce potential impacts to less-than-significant levels.

Table ES-1: Summary of Potential Impacts to Affected Environmental Resources

Environmental Resources

Sub-Category Alternative 1

Alternative 2

(Preferred

Alternative)

No-Action

Alternative

Land Use Negligible Negligible No Impact

Infrastructure & Utilities Adverse Beneficial, Long-term Adverse

Socioeconomics Beneficial;

Short-term

Beneficial;

Short-term

No Impact

Recreational Facilities Minor Adverse;

Short-term Minor Adverse;

Short-term No Impact

Soils Minor Beneficial;

Long-term

Minor Beneficial Long-term

Adverse; Long-Term

Climate and Air Quality Negligible.

Long -term

Negligible;

Long-term

No Impact

Noise Negligible;

Short-term

Negligible;

Short-term

No Impact

Hazardous Materials/Waste Negligible;

Short-term

Negligible;

Short-term

No Impact

Biological Resources

Terrestrial Vegetation No Impact No Impact

No Impact

Wildlife No Impact No Impact

No Impact

Migratory Birds No Impact No Impact No Impact v

Environmental Resources

Sub-Category Alternative 1

Alternative 2

(Preferred

Alternative)

No-Action

Alternative

Threatened and Endangered Species

Negligible;

Short-term

Negligible;

Short-term

No Impact

Water Resources

Minor Adverse;

Long-term Tidal Bottom: Minor Beneficial;

Long-term Water Quality:

Beneficial, Long-term Floodplain

Minor Adverse;

Long-term Tidal Bottom: Minor Beneficial; Long-term Water Quality: No Impact Floodplain

Minor Adverse;

Long-term Water Quality

Coastal Policies and Resources Negligible Minor, Adverse

Long-term No Impact

Cultural Resources Minor Adverse; Long-

Term

Minor Adverse;

Long-term No Effect

Key:

Minor = An impact that is not significant, but one that cannot be safely disregarded.

Negligible = An impact that is so small or unimportant that it may safely be disregarded.

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CONTENTS

Executive Summary ........................................................................................................................................ i

Acronyms and Abbreviations ...................................................................................................................... xiii

1 Purpose and Need for the Action

1.1 Introduction

1.2 Background

1.2.1 United States Coast Guard Mission

1.2.2 ANT Tybee

1.2.3 CGC Pompano

1.2.4 Existing Facilities

1.2.5 Fort Pulaski National Monument

1.3 Purpose of Proposed Action

1.4 Need for Proposed Action

1.5 Agency and Public Involvement Process

1.5.1 Agency Coordination/Consultation

2 Description of the Proposed Action and Alternatives

2.1 Description of the Proposed Action

2.2 Alternatives for Evaluation

2.2.1 Planning Process/Alternatives Development

2.2.2 Alternative 1: Rebuild Option 1

2.2.3 Alternative 2: Rebuild Option 2 (Preferred Alternative)

2.2.4 No Action Alternative

2.2.5 Protection Measures, Permits and Compliance

2.3 Alternatives Examined but Eliminated from Further Analysis

3 Affected Environment

3.1 Resources Eliminated from Detailed Analysis

3.1.1 Submerged Aquatic Vegetation

3.1.2 Public Health and Safety

3.1.3 Visual/Aesthetic Resources

3.2 Land Use

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3.3 Utilities and Infrastructure

3.3.1 Infrastructure

3.3.2 Utilities

3.4 Socioeconomic Environment

3.4.1 Population and Demographics

3.4.2 Employment and Income

3.4.3 Housing

3.5 Recreational Facilities

3.6 Fire, Rescue, and Police Services

3.7 Physical Environment

3.7.1 Geology, Topography, and Soils

3.7.2 Air Quality

3.7.3 Noise

3.7.4 Hazardous Materials/Waste

3.8 Biological Resources

3.8.1 Vegetation

3.8.2 Wildlife

3.8.3 Migratory Birds

3.8.4 Threatened and Endangered Species

3.8.4.1 Federally Listed Species

3.8.4.2 State Listed Species

3.8.5 Essential Fish Habitat

3.9 Water Resources

3.9.1 Surface Waters

3.9.2 Groundwater

3.9.3 Wetlands

3.9.4 Floodplains

3.9.5 Coastal Policies and Resources

3.10 Cultural Resources

3.10.1 Overview

3.10.2 Area of Potential Effect

viii

3.10.3 Archaeological Resources

3.10.4 Historic Resources

4 Environmental Consequences

4.1 Land Use

4.1.1 Environmental Criteria

4.1.2 Impacts from Alternative 1: Rebuild Option 1

4.1.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.1.4 Impacts from the No Action Alternative

4.2 Infrastructure and Utilities

4.2.1 Environmental Criteria

4.2.2 Impacts from Alternative 1: Rebuild Option 1

4.2.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.2.4 Impacts from the No Action Alternative

4.3 Socioeconomic Environment

4.3.1 Environmental Criteria

4.3.2 Impacts from Alternative 1: Rebuild Option 1

4.3.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.3.4 Impacts from the No Action Alternative

4.4 Recreational Facilities

4.4.1 Environmental Criteria

4.4.2 Impacts from Alternative 1: Rebuild Option 1

4.4.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.4.4 Impacts from the No Action Alternative

4.5 Geology, Topography, and Soils

4.5.1 Environmental Criteria

4.5.2 Impacts from Alternative 1: Rebuild Option 1

4.5.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.5.4 Impacts from the No Action Alternative

4.6 Air Quality

4.6.1 Environmental Criteria

4.6.2 Impacts from Alternative 1: Rebuild Option 1

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4.6.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.6.4 Impacts from the No Action Alternative

4.7 Noise

4.7.1 Environmental Criteria

4.7.2 Impacts from Alternative 1: Rebuild Option 1

4.7.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.7.4 Impacts from the No Action Alternative

4.8 Hazardous Materials/Waste

4.8.1 Environmental Criteria

4.8.2 Impacts from Alternative 1: Rebuild Option 1

4.8.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.8.4 Impacts from the No Action Alternative

4.9 Biological Resources

4.9.1 Environmental Criteria

4.9.2 Impacts from Alternative 1: Rebuild Option 1

4.9.3 Impacts from the Proposed Action (Alternative 2: Rebuild Option 2)

4.9.4 Impacts from the No Action Alternative

4.10 Water Resources

4.10.1 Surface Waters

4.10.1.1 Environmental Criteria

4.10.1.2 Impacts from Alternative 1: Rebuild Option 1

4.10.1.3 Impacts from Proposed Action (Alternative 2: Rebuild Option 2)

4.10.1.4 Impacts from the No Action Alternative

4.10.2 Groundwater

4.10.2.1 Environmental Criteria

4.10.2.2 Impacts from Alternative 1: Rebuild Option 1

4.10.2.3 Impacts from Proposed Action (Alternative 2: Rebuild Option 2)

4.10.2.4 Impacts from the No Action Alternative

4.10.3 Wetlands

4.10.3.1 Environmental Criteria

4.10.3.2 Impacts from Alternative 1: Rebuild Option 1

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4.10.3.3 Impacts from Proposed Action (Alternative 2: Rebuild Option 2)

4.10.3.4 Impacts from the No Action Alternative

4.10.3.5 Exemption from NPS Wetland Statement of Findings Requirements

4.10.4 Floodplains

4.10.4.1 Environmental Criteria

4.10.4.2 Impacts from Alternative 1: Rebuild Option 1

4.10.4.3 Impacts from Proposed Action (Alternative 2: Rebuild Option 2)

4.10.4.4 Impacts from the No Action Alternative

4.10.5 Coastal Policies and Resources

4.10.5.1 Environmental Criteria

4.10.5.2 Impacts from Alternative 1: Rebuild Option 1

4.10.5.3 Impacts from Proposed Action (Alternative 2: Rebuild Option 2)

4.10.5.4 Impacts from the No Action Alternative

4.11 Cultural Resources

4.11.1 Environmental Criteria

4.11.2 Impacts from Alternative 1: Rebuild Option 1

4.11.3 Impacts from Proposed Action (Alternative 2: Rebuild Option 2)

4.11.4 Impacts from the No Action Alternative

5 Comparison of Alternatives and Conclusions

5.1 Comparison of the Environmental Consequences of the Alternatives

5.2 Conclusion

6 List of Preparers

7 Consultation and Coordination

8 References xi

TABLES

Table ES-1: Summary of Potential Impacts to Affected Environmental Resources ..................................... iv

Table 1-1: Existing Shore Infrastructure

Table 1-2: Facility Requirements versus Existing Shore Infrastructure Summary

Table 2-1 Ranking of Wastewater Treatment Alternatives and Current System

Table 2-2: USCG Facility Planning Advantages and Disadvantages of Alternative 1

Table 2-3: USCG Facility Planning Advantages and Disadvantages of Alternative 2

Table 2-4: USCG Facility Planning Advantages and Disadvantages of the No Action Alternative

Table 2-5: Potential Federal Permitting Matrix

Table 3-1: U.S. Census Bureau Population Estimates Program (PEP) Demographic Information 2019 .. 29

Table 3-2: U.S. Census Bureau PEP Ethnic Profile 2019

Table 3-3: American Community Survey (ACS) 5-Year Estimates Data Profile Employment/Income Rates

Table 3-4: U.S. Census Bureau PEP Housing Unit Data 2019 & ACS 5-Year Estimates Data Profile

Vacant Housing 2018

Table 3-5: Attainment Status for Chatham County for Criteria Pollutants

Table 3-6: Protected Species with Suitable Habitat Near USCG Station Tybee

Table 3-7: EFH and HAPC Near USCG Station Tybee

Table 3-8: Applicable Coastal Policies for Resources Identified

Table 5-1: Summary of Potential Impacts to Affected Environmental Resources

Table 6-1: List of Preparers

Table 7-1: Consultation and Coordination List xii

FIGURES

Figure 1.1: Site Location Map

Figure 1.2: Project Location Map Station Tybee

Figure 1.3: Fort Pulaski National Monument

Figure 2.1: Current Site Layout of Station Tybee

Figure 2.2: Alternative 2 – Proposed Conceptual Site Layout of Station

Figure 2.3 Proposed Wastewater Treatment System Upgrade Area

Figure 2.4 Proposed Water Supply System Upgrade Conceptual Layout

Figure 2.5 Proposed NPS Boat Ramp Upgrade Conceptual Layout

Figure 3.1: Mapped Soils in Project Area

Figure 3.2: Protected Species Habitat Map

Figure 3.3: Waters of the U.S

Figure 3.4: Floodplains

Figure 3.5 Area of Potential Effect – Aboveground

Figure 3.6: Looking west toward Station Tybee (in right background) from Park Headquarters

APPENDICES

Appendix A Agency Consultation and Coordination Correspondence

Appendix B Section 106 Consultation and Native American Consultation

Appendix C Coastal Zone Management Act Consistency Determination

Appendix D Cultural Resources Overview xiii

ACRONYMS AND ABBREVIATIONS

ACS American Community Survey

ANT Aids to Navigation Team

AOR area of responsibility

APE area of potential effect

BA biological assessment

BMP best management practice

CAA Clean Air Act

CEQ Council on Environmental Quality

CEU Civil Engineering Unit

CFR Code of Federal Regulations

CGC Coast Guard Cutter

CMP coastal management program

CO carbon monoxide

COMDTINST Commandant Instruction

CPS ASEC Annual Social and Economic Supplement to the Current Population Survey

CWA Clean Water Act

DHS Department of Homeland Security

E endangered

EA Environmental Assessment

EDDA Environmental Due Diligence Audit

EFH Essential Fish Habitat

EIS Environmental Impact Statement

EO Executive Order

EP Execution Proposal

EPD Environmental Protection Division (GADNR)

ESA Endangered Species Act

FEMA Federal Emergency Management Agency

FOC Full Operational Capacity

FONSI Finding of No Significant Impact xiv

Fort Pulaski Fort Pulaski National Monument

GADNR Georgia Department of Natural Resources

GHG greenhouse gas

GPA Georgia Port Authority

GSF gross square feet

GSMM Georgia Stormwater Management Manual

HAPC Habitat Area of Particular Concern

IAA Interagency Agreement

IRMA Integrated Resource Management Applications µg/m3 microgram per cubic meter

MBTA Migratory Bird Treaty Act

MHW mean high-water

MMB Multi-Mission Building

MOA Memorandum of Agreement

MSA metropolitan service area

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NMFS National Marine Fisheries Service

NO2 nitrogen dioxide

NOAA National Oceanic and Atmospheric Administration

NPDES National Pollutant Discharge Elimination System

NPS National Park Service

NRCS National Resource Conservation Service

NRHP National Register of Historic Places

O3 ozone

OCGA Official Code of Georgia

PAL Personnel Allotment List

PEP Population Estimates Program

PM10 and PM2.5 particulate matter

PP Planning Proposal xv ppm parts per million

PSD Prevention of Significant Deterioration

RCRA Resource Conservation and Recovery Act

SAR search and rescue

SAV submerged aquatic vegetation

SHPO State Historic Preservation Officer

SIP Stat Implementation Plan

SO2 sulfur dioxide

SOF Statement of Findings

T threatened

USACE U.S. Army Corps of Engineers

U.S.C. United States Code

USCG U.S. Coast Guard

USDA U.S. Department of Agriculture

USEPA United States Environmental Protection Agency

USFWS U.S. Fish and Wildlife Service

VOC volatile organic compound

WPB Coastal Patrol Boat

WOTUS Waters of the U.S.

1 PURPOSE AND NEED FOR THE ACTION

1.1 Introduction

This Environmental Assessment (EA) evaluates the proposal by the United States Coast Guard (USCG) and proposed alternatives to rebuild hurricane-damaged facilities by constructing a new Multi-Mission

Station Facility (hereafter referred to as the Multi-Mission Building [MMB]) and demolishing existing onshore facilities. Also included in the USCG proposal are repair of shoreline riprap, upgrade of existing water supply and wastewater treatment systems, and upgrade of the National Park Service (NPS) boat ramp (the Proposed Action). Construction of the MMB would replace aging facilities and multiple onshore buildings damaged during Hurricane Matthew in 2016 at Station Tybee (the Station), including the Station

Building. Personnel and functions at Station Tybee would be located in the new MMB upon its completion.

NPS was invited by the USCG, in a letter dated September 17, 2002, to be a Cooperating Agency, and

NPS agreed in a letter dated October 1, 2020 to be a Cooperating Agency. As a Cooperating Agency, the NPS assisted the USCG in developing the NEPA EA in order to ensure that pertinent NPS mission statements, legislative authorities, and policies were duly considered when developing any alternatives, related management actions, or options that could potentially affect the Fort Pulaski National Monument.

This EA has been prepared in accordance with the National Environmental Policy Act of 1969 (NEPA; 42

United States Code [U.S.C.] §§ 4321 et seq.); the President’s Council on Environmental Quality (CEQ)

Regulations Implementing the Procedural Provisions of NEPA (40 Code of Federal Regulations [CFR]

Parts 1500-1508); Department of Homeland Security (DHS) Management Directive 023-01001-01 (series)

I; and Coast Guard Commandant Instruction (COMDTINST) 5090.1, U.S. Coast Guard Environmental

Planning Policy, and NPS Director’s Order 12 for use by the USCG and NPS in making separate findings on the significance of the Proposed Action.

This EA has been completed to assist the USCG in making an informed decision on which alternative is appropriate for the rebuild of Station Tybee. The information and analysis contained within this EA will determine whether implementation of the Proposed Action would have a significant impact on the environment, requiring preparation of an Environmental Impact Statement (EIS). If no significant impacts would occur, a Finding of No Significant Impact (FONSI) would be appropriate. The EA will also allow the

NPS to determine if the improvements included in the Proposed Action are appropriate for Fort Pulaski

National Monument (referred to by the NPS as the Park Area) and consistent with the Park Area’s

General Management Plan and other applicable laws. Review and approval by the NPS of proposed improvements is subject to compliance with NEPA.

1.2 Background

1.2.1 United States Coast Guard Mission

The USCG employs approximately 38,000 active duty members and represents the seventh largest navy in the world. The USCG is a military service that is part of the DHS. In the past, however, upon a declaration of war or as directed by the U.S. Commander-in-Chief, the USCG has operated under the authority of the United States Navy and Department of Defense. USCG operations are divided into

Atlantic and Pacific commands, which are then subdivided into nine districts. Each district is further divided into sectors that are responsible for protecting inland waterways and coastal waters within the

U.S. exclusive economic zone or any waters within 200 nautical miles of the shoreline.

The U.S. maritime domain includes more than 95,000 miles of coastline and, over time, the USCG mission has evolved to encompass a variety of maritime services related to national defense, law enforcement (e.g., natural resources and counter-narcotics operations), search and rescue (SAR), transportation, and waterways management, among others. In 2002, in response to the September 11, 2001 terrorist attacks, Congress approved the creation of the DHS. The DHS was designed to consolidate and coordinate domestic counterterrorism efforts, and the reorganization established the

USCG as the lead agency for maritime homeland security.

The Station, assigned to Sector Charleston, USCG District 7, is located north of Tybee Island, Georgia, and east of downtown Savannah, Georgia. Figure 1.1 depicts the Site Location Map for the Station. The

Station occupies an approximate 3.1-acre parcel of land under an Interagency Agreement (IAA) with the

NPS, Fort Pulaski National Monument (hereinafter referred to as “Fort Pulaski”) on Cockspur Island.

Figure 1.2 shows the Project Location Map for Station Tybee and Areas A, B, and C (the Action Area where the Proposed Action and alternatives would occur).

The Station historically responds to approximately 250 SAR cases per year. Station Tybee is also host to both Aids to Navigation Team (ANT) Tybee and Coast Guard Cutter (CGC) POMPANO (WPB 87310), with different missions and areas of responsibility (AOR) as described in subsequent sections.

Figure 1.1: Site Location Map

Figure 1.2: Project Location Map Station Tybee

The Station is located near the mouth of the Savannah River on Cockspur Island, Chatham County, Georgia. Cockspur Island is a small island located on the southern bank of the Savannah River, west of the City of Tybee Island. The majority of Cockspur Island is within NPS Fort Pulaski National Monument.

Section 1.2.5 provides background information on Fort Pulaski. The onshore portion of Station Tybee exists on the approximate 3.1-acre parcel of land occupied and used by the USCG under an IAA between the NPS and the USCG, which was signed by both agencies in 1980 and then updated and signed by both agencies in March 2020. The IAA describes the stipulations regarding maintenance and improvements to the Station and other Fort Pulaski property. Those stipulations include the following with regard to improvements under the Proposed Action:

To comply with current resiliency requirements as well as to minimize impact on the historical site, the

Coast Guard will construct a building with the smallest practical footprint. Building design and height are to be reviewed and approved in writing by the NPS.

The Coast Guard will use the area identified as Area A for the purpose of installing an improved wastewater treatment system. The Coast Guard will allow NPS access and use of the wastewater treatment system. The Coast Guard will be responsible for all costs associated with the use/upgrade and maintenance of the wastewater treatment system.

To improve the operational capacity of the Coast Guard, the Coast Guard will use Area B for the purpose of improving and utilizing the existing boat ramp.

To improve the resiliency of the potable water system, the Coast Guard will make a one-time upgrade to the NPS owned well and pump house. All upgrades to the potable well system will be for the shared use of the Coast Guard and the NPS. The NPS will be responsible for maintaining all further upgrades and improvements to the potable well system.

The Coast Guard AOR for the Station is an area covering approximately 75 coastal miles seaward from

St. Helena Sound, South Carolina (32-27.5N 080-25.0W) to position 32-02N 079-54W; then southwesterly to position 31-18N 080-41W; then northwesterly to the southern tip of St. Catherine's Island

(31-33N 081-11W). This includes miles of rivers, creeks, tributaries, and marshes. Station Tybee’s specific responsibilities include, but are not limited to:

Provide SAR and support in accordance with Seventh Coast Guard District standard operation procedures and the SAR plan.

Maintain a state of military readiness guarding U.S. shores for DHS.

Provide resources for enforcement of federal laws and treaties and provide periodic support for other federal, state, and local agencies. Station Tybee will maintain a visible, aggressive Maritime Law

Enforcement profile in its AOR.

Support other USCG units as needed.

Provide support for local community services and organizations and be an active member of the community.

The Station has one 45-foot Response Boat-Medium II and three 29-foot Response Boat-Small II. The

Response Boat-Medium II is designed for multiple missions including SAR, law enforcement, drug and migrant interdiction, and port, waterway, and coastal security. The Response Boat-Small II is a multi-mission platform used for the full range of USCG missions including SAR, vessel boarding team deployment and law enforcement missions, port security, drug and migrant interdiction, and environmental response operations. (CGC POMPANO – a District 7 asset – is also stationed at Station

Tybee, as discussed below.)

The existing waterfront infrastructure includes the main pier, access pier, north floating dock for CGC

POMPANO, and south floating dock for small boats. The existing sizes of the waterfront facilities are sufficient for the operations at the Station. Water depths at the Station are sufficient to support operations.

1.2.2 ANT Tybee

ANT Tybee, located within the Station, is responsible for maintaining all federally owned buoys, day-boards, and other aids to navigation within its AOR. The ANT Tybee AOR extends along the full extent of coastal Georgia, the Savannah River, and eastern Georgia tributaries. ANT Tybee has one 25-foot trailer-able Aids to Navigation Boat homeported at Station Tybee.

1.2.3 CGC Pompano

CGC POMPANO (formerly TARPON) is an 87-foot Coastal Patrol Boat (WPB) homeported at Station

Tybee. CGC POMPANO missions include SAR, Maritime Law Enforcement boarding of commercial and recreational vessels, and port security. CGC POMPANO is located within the Station. CGC POMPANO also is active in public affairs and hosts tours for local high schools and other organizations. CGC

POMPANO’s AOR extends from the South Carolina/Georgia border southward to Key West, Florida including all waters within the Sector Charleston AOR. CGC POMPANO also operates one small cutter boat (with trailer on site).

1.2.4 Existing Facilities

The Station, ANT Tybee, and CGC POMPANO currently operate out of a total of 23,936 gross square feet (GSF) of facility space including two primary buildings (101 and 109) and numerous smaller support facilities. Table 1-1 details the existing Station Tybee facilities based on the current Shore Facilities

Inventory. Station Building 101 houses the Station’s offices, galley and mess deck, training and conference space, duty berthing rooms, and other personnel support space. Shop Building 109 houses

Station Tybee shops, shop storage space, a fitness room, and other shop support spaces. It has a finished floor elevation of 15.94 feet (North American Vertical Datum of 1988) and a roof peak elevation of

46.14 feet, which is approximately 36 feet above ground level. Construction of the ANT Tybee boat maintenance and storage building (Building 115) was completed in 2009 to relieve some of the congestion.

Table 1-1: Existing Shore Infrastructure

Facility Number Facility Name Year Built Area (GSF)

101 Station Building 1983 15,857

102 Flammable Storage Building 1996 102

103 Recreation Pavilion 1993 629

109 Shops Building 1983 3,852

110 Hurricane Shed 1990 288

113 Grounds Maintenance Shed 1990 171

115 ANT Tybee Storage Building #2 2009 1,725

116 ANT Tybee Storage Building #1 2009 320

117 CGC POMPANO Storage Building 2000 840

121 Paint Locker - 84

RO1 Open Gen. Storage 68

Total GSF 23,936

1.2.5 Fort Pulaski National Monument

Fort Pulaski National Monument is located west of Tybee Island, Georgia and consists of 5,623 acres of land on Cockspur and McQueen’s islands (Figure 1.3). The Fort was constructed in the 19th century as part of a protective chain of forts built to protect the eastern seaboard cities from attack by the British, French, and Spanish. Fort Pulaski is a historic district listed on the National Register of Historic Places.

The park contains a range of significant historical and natural resources. Of the 5,623 acres of Fort

Pulaski National Monument, nearly 5,000 acres are tidal salt marsh. Recreational visitation to the park has averaged approximately 339,000 individuals annually since 1995, with typical peak visitation between

April and July (NPS 2013). The purposes of Fort Pulaski National Monument are to:

Preserve and protect the 19th century masonry fort and its associated structures, and interpret its roles in coastal fortifications, military technology, and the Civil War.

Preserve and protect other military structures, other governmental structures, and archeological resources associated with various military developments and fortifications on Cockspur Island.

Preserve and protect approximately 5,000 acres of nearly pristine salt marsh on McQueen’s and

Cockspur Islands that constitute the largest portion of the national monument and interpret this important coastal ecology for the education, inspiration, and enjoyment of visitors.

Figure 1.3: Fort Pulaski National Monument

1.3 Purpose of Proposed Action

The purpose of the Proposed Action is to accomplish the Station’s various missions from its current location, which is centrally located within its AOR and provides sheltered but quick access to marine waters off the coasts of Georgia and South Carolina within its AOR, by rebuilding storm-damaged and aging facilities at the Station. Implementation of the Proposed Action would equip the Station with modern facilities that comply with today’s standards and harden its infrastructure for future resiliency.

1.4 Need for Proposed Action

There are three distinct issues that are driving the need for the Proposed Action: (1) aging facilities that no longer meet Coast Guard needs (2) damage to facilities from Hurricane Matthew and prior storm events and (3) the need to construct resilient facilities to support mission execution, especially during future storm events.

The Station is a multi-mission USCG Station, constructed in 1983, which has since added personnel and has seen deterioration in the facilities. In May 2008, District Seven outlined the operational constraints encountered by the unsatisfactory facilities. In 2019, a USCG proposal identified that the Station is currently operating at less than its full capability due to the current condition of the shore facilities and waterfront infrastructure. These structures have reached or exceeded their service life, which was exacerbated by storm damage and deterioration.

Hurricane Matthew made landfall on October 8, 2016 as a Category 1 hurricane just south of

McClellanville, South Carolina, in the Cape Romain Wildlife Sanctuary. The storm produced upwards of

12 inches of rain along the coast and winds of up to approximately 88 miles per hour at landfall (NOAA et

al. 2017). The combined impacts from high winds and rain resulted in damage to the second floor of the

Station building, and storm surge resulted in damage to the rip-rap along the shoreline of the Station.

Damaged waterfront riprap/structures allow scouring to produce sinkholes and subsidence to Station property, which has to be continually repaired. Recent Civil Engineering Unit (CEU) inspections (March

2019) have rated the structures as mostly in poor condition.

A quantitative analysis of what is required for basic facility operations versus existing assets is provided in

Table 1-2. Comparing the total facility requirements to the existing facilities at Station Tybee, the Station has less than 70 percent of the building space required to effectively support the mission. The mission and personnel growth since the establishment of the Station has far exceeded the provision of facility space. Typical reasonable space utilization (existing compared to required) figures range from 0.95

(shortfall) to 1.15 (excess), and the capacities of all units at Station Tybee are below the reasonable space utilization range.

Table 1-2: Facility Requirements versus Existing Shore Infrastructure Summary

Existing USCG Unit Required

Infrastructure

Existing

Infrastructure Gap Existing as

Proportion Required

STA Station Tybee 20,283 15,857 4,426 0.782

ANT Tybee 5,802 2,045 3,757 0.352

CGC POMPANO 965 840 125 0.87

Total 27,068 18,742 8,308 0.69

Note: All units in square feet and gross floor area.

Station Building 101 (the largest building) presents the most serious problems with respect to long-term sustainability. It is in poor condition, especially regarding structural integrity. This building is a wood frame structure built on wood/steel trusses on a woodpile foundation, making it vulnerable to adverse impacts from local environmental conditions and natural events such as Hurricane Matthew. Much of the land mass along the north and west shores of Cockspur Island was built up with dredge spoil during the 1880s (Alexander 2008). Station Building 101 has experienced settling over the years, which has resulted in required installation of numerous jacks to counteract the settling. Additionally, because the air conditioning constantly runs during the summer, the system requires frequent servicing and mold removal. Station Tybee Building 101 also lacks a wet room and a space sufficient for all-hands gatherings.

As a result of poor living conditions in duty-berthing rooms, a rehabilitation project was executed in 2006.

During project execution, numerous deficiencies were discovered including deteriorating floor trusses, sub-floors and floors, doors and frames, and exterior handrails and railings. The restroom facilities on the first deck were also found to be in disrepair, failing to meet Americans with Disabilities Act standards.

From an operational standpoint for the Station personnel/mission, covered small boat maintenance space is a space deficiency of high priority. Shop Building 109 is structurally sound but is poorly configured for daily operations. Work bays were originally designed as auto garages and do not provide sufficient overhead clearance for accommodating small boat maintenance.

The more recently completed ANT Tybee boat storage and maintenance building is sufficient to accommodate two boats, but shop space and storage space are not all collocated and are inadequately sized. Also, vehicular accessibility to the boat bay and maneuvering of boats on trailers is difficult due to existing physical constraints. Permanent storage and additional file storage space is needed.

Additionally, the shore facilities do not meet mission requirements as outlined above for the following reasons:

The Station was originally constructed to accommodate 25 personnel; the current number of personnel assigned to the Station stands at approximately 55, which includes nearly 40 active-duty personnel assigned to the Station, an additional 11 to 12 assigned to CGC POMPANO, and six personnel assigned to ANT Tybee. The number of personnel assigned to Station Tybee could increase to 45 for active-duty personnel in the future if current plans are approved. This increase in personnel from the initial establishment of the Station has caused insufficient facilities and makeshift offices and shops to be constructed. Overcrowding has hindered mission readiness and the productivity of the units at the Station. There are also approximately 30 reservists assigned to the

Station. The deficiencies were documented by the USCG in May 2008. In July 2008, the Coast

Guard approved the recapitalization or relocation of Station Tybee. Following Hurricane Matthew, the

USCG developed in May 2019 a plan to rebuild facilities at the Station pursuant to the USCG Civil

Engineering Manual (COMDINST M11000.11B) and the Shore Facilities Standards Manual

(COMDISNT M11012.9, Vol 1).

When the Station was originally constructed, it was assigned three small boats. Now, the Station is assigned three 29-foot small boats plus one 45-foot medium boat in addition to ANT Tybee’s 25-foot small boat and CGC POMPANO’s 87-foot WPB and small boat. This has caused overcrowding for boat mooring and trailer parking. There is no boat ramp on site, and small boats must be transported to a boat ramp on Lazaretto Creek at Tybee Island. While this ramp is adequate in size and location for mission support, a ramp on site would be preferable. However, the rapid Savannah River currents make this option difficult for launching/retrieving small boats without some adjacent floating dock to facilitate control of these vessels. Larger vessels, such as the 45-foot medium boat and CGC

POMPANO, cannot be trailered and are dry docked at area shipyards when in need of out-of-water maintenance.

The work bays and shops were originally designed for auto repair and do not have sufficient overhead space for boat maintenance. This causes all boat maintenance to occur outdoors. Working outdoors decreases the quality of the maintenance, as Cockspur Island is subject to excessive heat, rain, and insects.

The Main Station Building (Building 101) is a wood frame structure built on wood/steel trusses on a woodpile foundation, which is not appropriate for the local environmental conditions. The building has deteriorated since the time of construction in1983, and deficiencies continue. Additionally, the roof of the Station Building was damaged during Hurricane Matthew and resulted in the growth of mold, making the second floor uninhabitable and unusable. The trailers between the Station Building and the road are currently used as living quarters for the officers to replace currently unusable space on the second floor of the Station Building. There is a need to provide permanent living quarters and other required space.

The current sanitary wastewater system is overtaxed by demand and requires approximately two times more septic system capacity to meet current demands (PHE-BAKER JV, LLC. 2020).

There is a need to construct resilient facilities to support mission execution, especially during future storm events. The Station is vulnerable to future hurricanes and high-water events, both due to its location within the floodplain and because of the material condition of the buildings. There is a need to make the

Station resilient, which includes repairing the riprap along the Station shoreline that was damaged during

Hurricane Matthew to reduce vulnerability to future hurricanes and to upgrade the water supply system, which provides potable water to the Station. The resiliency principles include, but are not limited to, mitigation measures against flooding, storm surge, or exposure as well as other appropriate safeguards to protect shore facilities, waterfront infrastructure, and critical systems – including distribution systems for supporting utilities (e.g., water/sewer/drainage, electricity, information technology).

1.5 Agency and Public Involvement Process

Pursuant to the requirements of NEPA (40 CFR 1506.6), this EA is subject to public involvement.

Consideration of the views and information provided by all interested persons promotes open communication and enables better decision-making. Agencies, organizations, and members of the public with a potential interest in the Proposed Action, including minority, low-income, and disadvantaged groups, are encouraged to participate. A record of public involvement, agency coordination, and Native

American consultation associated with this EA is provided in Appendix A and Appendix B. A complete list of agencies and individuals consulted during preparation of this EA is included in Section 7.0.

1.5.1 Agency Coordination/Consultation

Interagency and intergovernmental coordination is a federally mandated process for informing and coordinating with other governmental agencies regarding federal proposed actions. CEQ Regulations require intergovernmental notifications before making any detailed statement of environmental impacts.

This coordination also fulfills requirements under Executive Order (EO) 12372 (Intergovernmental Review of Federal Programs; superseded by EO 12416, and subsequently supplemented by EO 13132),…