Attch 1_SOW_Culvert 10 SLD 30.pdf

STATEMENT OF WORK

ENVIRONMENTAL ASSESSMENT

For

CULVERT 10 REPLACEMENT

At

VANDENBERG SPACE FORCE BASE

Santa Barbara County, California

1 Introduction Space Launch Delta 30 (SLD 30) of the Department of the Air Force (DAF) at Vandenberg Space Force Base (VSFB), California proposes to replace Culvert 10 on Coast Road. SLD 30 is the lead federal agency responsible for complying with the NEPA and other associated, relevant laws and regulations for the proposed federal action.

This Statement of Work (SOW) defines preparation requirements for an Environmental Assessment (EA) and California Coastal Commission (CCC) Negative Determination (ND) for the proposed Culvert 10 Replacement. Guidance on the standards for meeting these requirements will be provided by the Installation Management Flight of the 30th Civil Engineer Squadron (30 CES/CEI) at SLD 30.

2 Project Description and Justification The DAF Proposed Action will eliminate the risk for Coast Road to fail at this location. Culvert 10 has deteriorated, and this area is at significant risk of sinking. Coast Road is a critical transportation route that supports transport of billion dollar launch assets. The DAF proposes to remove and replace the entirety of the existing culvert along the same alignment and excavate the ground surrounding the culvert. The Proposed Action includes measures that will slow the flow of water at the outfall to reduce or eliminate any further erosion of the downstream drainage resulting from Culvert 10 flows. This project requires an EA due to impacts to an eligible historic property. SLD 30 is completing natural and cultural resource surveys and applicable consultations (Section 7 and Section 106) independently and will provide these to the contractor for inclusion in the EA.

3 Scope of Services The Culvert 10 Replacement project requires an Environmental Assessment (EA) and California Coastal Commission (CCC) Negative Determination (ND). No field work is required to complete these documents.

3.1 Environmental Assessment

SLD 30 has determined that the proposed federal action constitutes a major federal action under the 32 Code of Federal Regulations (CFR) Part 989.3(e)(7). As such, the DAF must comply with the National Environmental Policy Act of 1969 (NEPA) (Public Law 91-190, 42 United States Code Sections 4321 through 4347) and the Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of the NEPA (40 CFR Parts 1500 through 1508). The EA will serve to maintain DAF NEPA compliance as well as guide DAF decision-makers through project design, construction, and implementation.

The contractor will prepare an administrative draft, second draft, after that as many drafts that are needed to address all comments, final draft (for public circulation), and final EA. EA preparation shall be in accordance with 40 CFR Parts 1500 – 1508. The contractor will coordinate with the DAF Environmental Planner to determine the number of days the draft EA will be available to the public (typically 30 days) and will oversee public review of the EA once SLD 30 has reviewed and approved the final draft. The contractor shall plan project activities, including the development, implementation, and maintenance of project schedules, status of resources, report(s) on the activities, and progress toward accomplishing DAF compliance with the NEPA.

The EA should provide sufficient analysis to determine whether to prepare an Environmental Impact Statement (EIS) or a Finding of No Significant Impact (FONSI). If the EA results in a FONSI, the contractor shall prepare a draft FONSI for review and a final FONSI. As a finding contained in the draft FONSI, a Finding of No Practicable Alternative (FONPA) shall be prepared since the Proposed Action will occur within the 100-year floodplain. The FONPA must discuss why no other practicable alternative exists to avoid impacts.

EA Preparation and Planning The contractor shall:

• Begin work within 30 days of receiving Notice to Proceed

• Identify within the EA any required or recommended measures necessary to reduce any adverse environmental impacts. Incorporate required measures into the project description.

• Coordinate necessary meetings with the 30 CES/CEIEA Environmental Planner. Purpose of the meetings may include, but are not limited to, contract discussions, progress reviews, project scoping, planning, project status, and general information exchange concerning current and future activities including available mapping, specifics regarding the boundaries of the project sites, and an inventory and details of any known or suspected contaminated sites.

• Establish an EA schedule in coordination with the 30 CES/CEIEA Environmental Planner.

• Coordinate with the 30 CES/CEIEA Environmental Planner to receive required project specific information from SLD 30 personnel (subject matter experts).

• Conduct Air Emissions Modelling. Since this is a DAF EA, contractor shall use the Air

Conformity Applicability Model (ACAM) to estimate emissions from the action (not the CalEE model). This is a DAF regulatory requirement that is set forth in AFMAN 32-7002, Chapter 4. Contractor shall also use the California Emissions Estimator Model

(CalEEMod) and insert results and findings associated with state emissions thresholds as an Appendix.

Writing Style and Content The contractor shall:

• Write the EA to follow 40 CFR Part 1502.10 except that an Index is not necessary.

• Follow 30 CES/CEIEA’s most current version of the “Style Guide and Standards for

Writing Environmental Assessments.”

• Write the EA using active voice to maximum extent practicable in clear, plain language such that any adult member of the community would understand the information and conclusions presented.

• Limit technical terms and complex concepts, especially unfamiliar acronyms and abbreviations.

• Include clear, accurate, and legally defensible citations, and scientific and technical conclusions.

• Use parenthetical citations (not footnotes) and fully record sources in a complete bibliography.

• Identify incomplete and/or unavailable information and make environmental forecasts despite limitations.

Analysis of Alternatives

• The contractor shall analyze reasonable alternatives to the proposed action and the “no action” alternative in the EA, as fully as the proposed action alternative.

• “Reasonable” alternatives are those that meet the purpose and need for the proposed action and that would cause a reasonable person to inquire further before choosing a particular course of action. Reasonable alternatives are not limited to those directly within the power of the DAF to implement. They may involve another government agency or military service to assist in the project or even to become the lead agency. The contractor need not analyze highly speculative alternatives, such as those requiring a major, unlikely change in law or governmental policy. If the contractor identifies many reasonable alternatives, it may limit alternatives selected for detailed environmental analysis to a reasonable range or to a reasonable number of examples covering the full spectrum of alternatives.

• The contractor may expressly eliminate alternatives from detailed analysis, based on reasonable selection standards (for example, operational, technical, or environmental standards suitable to a particular project). In consultation with the 30 CES/CEIEA Environmental Planner, the appropriate DAF organization may develop written selection standards to firmly establish what is a “reasonable” alternative for a particular project.

They shall not so narrowly define these standards that they unnecessarily limit consideration to the proposal initially favored by proponents.

• The contractor shall consider and assess the environmental impacts of the “no action” alternative, except if rare instance of being excused by law. “No action” may mean either that current management practice will not change or that the proposed action will not take place. If no action would result in other predictable actions, those actions should be discussed within the no action alternative section. The discussion of the no action alternative and the other alternatives should be comparable in detail to that of the proposed action.

EA Structure and Timeline:

• Contractor must comply with the following guidance: 75-pages or fewer and 12 months measured from the date the notification to State, Tribal, or local agencies or governments of the proposed action occurs per 40 C.F.R. § 1506.6 and the date the draft EA, FONPA, and unsigned FONSI are made available to the affected public per 32 C.F.R. § 989.15(e).

EA Suggested Format:

1. Cover Page

a. Document Type (EA), Document Title, Document Date

b. Cover shall not include the preparer’s name or company logo.

2. Title Page

a. Includes same information as the cover plus the name and address of the preparer and the name and address of the proponent.

3. Table of Contents

4. List of Figures and List of Tables

5. Acronyms and Abbreviations

6. Chapter 1 - Purpose and Need for Action

7. Chapter 2 - Alternatives including the Proposed Action

8. Chapter 3 - Affected Environment

9. Chapter 4 - Environmental Consequences

10. Chapter 5 – List Agencies and Persons Contacted

11. Chapter 6 – List of Preparers

12. Chapter 7 – Distribution List

13. Chapter 8 – Bibliography and Appendices: The EA shall include associated documents in appendices, such as the Noise and Air Quality Analysis, and completed consultations, such as the CCC ND, Section 7, and Section 106 documents.

i. Air Quality Emissions Analysis is required. The contractor shall use Air Conformity Applicability Model (ACAM) software for this analysis and include in the body of the EA. California Emissions Estimator Model (CalEEMod) and insert results and findings associated with state emissions thresholds as an Appendix.

FONSI/FONPA

• Keep FONSI/FONPA brief; only rarely should a FONSI/FONPA exceed two typewritten pages.

• Clearly identify draft EAs and unsigned draft FONSIs/FONPAs as drafts and distribute via cover letter which will explain their purpose and need.

• Before the FONSI/FONPA is signed and action is implemented, allow sufficient time to receive comments from the public. The duration will reflect the magnitude of the proposed action and its potential for controversy. The greater the magnitude of the proposed action or its potential for controversy, the longer the time that shall be allowed for public review.

• In every case where an EA and FONSI/FONPA are prepared, the contractor and 30 CES/CEIEA Environmental Planner shall determine how much time will be allowed for public review. In all cases, other than classified actions, a public review period should be the norm unless clearly unnecessary due to the lack of potential controversy.

• Use appropriate DAF signature block on the FONSI/FONPA signature page. The Environmental Planner will provide the correct information to the contractor.

• Bind the signed FONSI/FONPA at the front of the Final EA.

Editing

• A qualified editor shall review the EA and FONSI/FONPA prior to each draft submittal and once before final printing.

• The editor shall not be the author of the EA or FONSI/FONPA.

• The editor shall review the document for spelling, grammar, clarity, and accuracy.

• The editor shall ensure that the EA complies with all structure and style guidance listed in this SOW.

Regulatory Consultations

• It is DAF policy that regulatory coordination with such agencies as the United States Fish and Wildlife Service (USFWS), the State Historic Preservation Office (SHPO) or the CCC shall be finalized prior to issuance of the EA for public review. Note that this policy does not apply to most permits. The DAF is completing USFWS and SHPO regulatory coordination independently for this project.

• The contractor shall incorporate pertinent language and mitigation requirements from resulting agency coordination into the EA.

Public Review

• Unless requested otherwise by 30 CES/CEIEA, the contractor shall issue the EA and FONSI/FONPA for a 30-day public review.

• Prepare a news release to post in local county newspapers. Prepare and attach a notice of availability letter to the draft EA. The CES/CEI Environmental Planner can provide acceptable examples of these documents. The contractor shall submit the news release and notice of availability letter to the CES/CEI Environmental Planner prior to posting. The SLD 30/Judicial Affairs (SLD 30/JA) and Public Affairs (SLD 30/PA) offices shall approve documents prior to posting.

• Submit news release in the Lompoc Record and the Santa Maria Times for three days each, including one Sunday.

• Distribute EA and FONSI/FONPA to libraries, individuals, and agencies as directed by the 30 CES/CEIEA Environmental Planner.

• 30 CES/CEIEA shall review public comments.

Issuance of Final EA and FONSI/FONPA

• Deliver one electronic copy of the final EA to 30 CES/CEIEA.

Table 1: EA Deliverables Deliverable # hard copies # e-copies

First Administrative Draft EA 0 1 Second Administrative Draft EA & FONSI/FONPA1 0 1 Final Draft EA/FONSI/FONPA (Public Review Copy) 21 1 Final EA/FONSI/FONPA (for final AF signature) 0 1 Final EA/FONSI/FONPA (with AF signature) 0 1

1 After this, as many drafts that are needed to address all comments prior to public review.

3.2 CCC Negative Determination

The federal government certified the California Coastal Management Program (CCMP) in 1977.

The enforceable policies of that document are Chapter 3 of the California Coastal Act of 1976. All consistency documents are reviewed for consistency with these policies. The Commission’s goal is to use the federal consistency process to provide open communication and coordination with federal agencies and applicants and provide the public with an opportunity to participate in the process. The Commission believes that this process allows it to authorize federal activities in manner that minimizes impacts to coastal resources and is consistent with the CCMP.

A Negative Determination (ND) includes a statement indicating that the proposed action will be undertaken in a manner that is consistent to the maximum extent practicable with the CCMP. The statement must be based upon an evaluation of the relevant enforceable policies of the management program, which must be included in the ND. The ND shall also include a detailed description of the activity, its associated facilities, and their coastal effects, and comprehensive data and information sufficient to support the DAF’s consistency statement. The amount of detail in the evaluation depends on the complexity of the project. The Contractor will work with DAF Environmental Planner to develop the above requirements.

Negative Determination Deliverables Deliverable Date Due or Days after award First Draft Negative Determination 60 days after the first EA draft is submitted.

Additional Administrative (if required) Negative Determination

30 days after Contractor receives comments from 1st draft

Final Negative Determination 30 days after Contractor receives comments from 2nd draft

SPECIAL CONDITIONS

• SLD 30 will furnish relevant materials, such as existing information and metadata format for GIS coverage, site documentation or other reports requested by the contractor.

• The contractor shall ensure that only qualified, competent personnel carry out the tasks outlined in this SOW. Competent is defined as registered professional or, where registration is not applicable, trained and certified with a degree in a related field of study.

Exceptions are administrative and support personnel who participate in document publication. All proposals MUST INCLUDE résumés and / or curricula vitae of key project personnel.

• All deliverables are property of the DAF. All materials gathered and/or developed in the performance of these tasks (e.g., digital photos) shall be returned to and become property of the DAF and shall not be used and/or distributed by the contractor without specific written permission of the 30 CES/CEIEA Project Manager.

• Deliverable Formats. All documents, including photographs and maps, shall be dated.

Final report shall be submitted in two electronic formats: (1) MS Word (*.doc), (2) Adobe Acrobat (*.pdf).

• All shape and linear files created for this project shall be provided to the government on a CD or other appropriate device (note: The use of USB sticks or “thumb drives” is prohibited by the DAF). GeoSpatial Data shall be consistent with the SLD 30 GeoBase Spatial Data Submittal Standards. Data should be accurate within 5 meters unless personnel safety is a factor.

• Defense Technical Information Center (DTIC) submittal. Contractor needs to register with DTIC then follow guidance on submitting documents.

• Public Disclosure: The contractor (nor staff) shall not give news releases or conduct media interviews concerning the work performed or results thereof. The installation PAO will release any information for public release. Direct all requests for information, including any citing the Freedom of Information Act, to the VSFB PAO and 30 CES/CEIEA Environmental Planner.

3.3 NOTIFICATION REQUIREMENTS

The Contractor is required to notify the 30 CES/CEIEA Environmental Planner of critical issues that may affect the contract performance and/or human health and the environment. The types of issues that require notification include, but are not limited to, health risks, spills, changes in critical personnel, and UXO. On critical issues, verbal notification must be made immediately, followed by written notification as soon as practical.