Signiture Page FONSI for CEAC EA.PDF

Cyber and Engineering Academic Center Supplemental Environmental Assessment December 2019

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FINDING OF NO SIGNIFICANT IMPACT

SUPPLEMENTAL ENVIRONMENTAL ASSESSMENT

FOR THE

THE CYBER AND ENGINEERING ACADEMIC CENTER AND PARKING STRUCTURE

UNITED STATES ARMY GARRISON – WEST POINT

WEST POINT, ORANGE COUNTY, NEW YORK

I. NAME OF ACTION

The United States Army Garrison (USAG) at West Point (WP), New York, has proposed the development of a state-of-the-art computer and engineering sciences academic building and underground parking structure on the campus of the United States Military Academy (USMA) at West Point. The new academic building, known as the Cyber and Engineering Academic Center (CEAC) fulfills the need for a collaborative science and engineering learning space enabling USMA cadets to experiment with and develop new and emerging technologies that will enable the United States Military to remain at the technological forefront of new battlefields, both physical and digital. The proposed parking structure would serve CEAC as well as address parking shortages within the USMA campus without increasing the footprint of surface parking.

II. DESCRIPTION OF ACTION

Proposed Action: The proposed CEAC building is a modification of a previously-approved construction effort known as the Multi-Purpose Academic Center (MPAC). The MPAC was assessed pursuant to the National Environmental Policy Act (NEPA) in 2012 but did not proceed to construction. The site and general purpose of the CEAC building are similar to MPAC; however, the Finding of No Significant Impact associated with the Supplemental Environmental Assessment (SEA) prepared for MPAC has expired.

Additionally, the CEAC project would result in potential adverse effects on the National Historic Landmark District (NHLD) at West Point. These circumstances require a re-assessment of the effort in an updated NEPA document.

The CEAC building would be constructed within the Central Zone/Cadet Zone of the USMA Campus, on the west side of Thayer Road, south of existing Building 606, and across Thayer Road from the existing Mahan Hall. The action would involve the demolition of four existing single-family residential structures (Quarters #5-#8) and an associated garage building (Building #20), an existing rock retaining wall, and an existing surface parking area. The residential structures are contributing elements to the West Point NHLD. The CEAC building site also incorporates the site of the former Central Apartments, which were previously demolished. The Central Apartments site is currently in use for construction staging and management for on-going construction and renovation efforts within the Central Zone.

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The new CEAC building would be approximately 136,000 square foot (SF) in total area and four stories in height. Two (2) enclosed pedestrian bridges are proposed: one spanning over Thayer Road to connect the CEAC to Mahon Hall, and the other to connect to Building 606. Rooftop signature meeting space (SMS) and colloquium space is also proposed. The rooftop spaces constitute the fourth floor of the CEAC building.

A two (2) level, 450-space parking structure would be constructed beneath the CEAC building. The parking structure would be restricted to use by authorized personnel and accessed from a driveway intersecting Thayer Road from the west. New hardscape is proposed to integrate the CEAC with the existing academic buildings and barracks located within the Central Zone at USMA. Existing thematic grotesques depicting engineering sciences salvaged from the previous demolition of Building 606 will be incorporated into the CEAC design to enhance the context sensitive design of the building and connect the CEAC building to the engineering and science education legacy of West Point.

In addition to the demolition of the residential buildings, redevelopment of the existing construction staging area, and construction of the CEAC building and parking structure, the Proposed Action includes the following elements:

• Extension of Thayer Walk pedestrian plaza to the south and relocation of the security guard booth located at the existing terminus of Thayer Walk.

• Stormwater management measures, including the use of Green Infrastructure Techniques based on the regulations of the New York State Department of Environmental Conservation (NYSDEC) and an underground stormwater detention to ensure stormwater quality.

• Construction of accessory components (i.e., site access/circulation and utility connections.)

Construction phase activities will include a 70-foot rock cut and excavation, requiring the disposal of approximately 345,000 cubic yards of rock and excavated material. Construction phase activities are anticipated to commence in the Autumn of 2019 and extend to the Summer of 2023.

Alternatives: The following alternatives to the Proposed Action were considered:

No Action

Existing substandard academic spaces would continue to be used for their existing purpose or upgraded and reconfigured as described in the Academic Building Upgrade Plan (ABUP) dated 01 December 2017, but engineering and computer sciences would not receive enhanced laboratory and collaborative learning spaces. No additional parking capacity would be provided. The No Action Alternate does not meet the purpose and need of providing collaborative, technologically-current learning spaces or additional parking capacity. Additionally, the ability for USMA to improve the potential to recruit quality cadets would be reduced. As a result, the No Action Alternate was not considered further.

Alternate A: Upgrade Existing Academic Spaces

Existing academic spaces at West Point were constructed more than 40 years ago, and while the spaces have been rehabilitated and improved over the intervening years, the structural design of the existing

3 | P a g e buildings limit their adaptability for use in the study of emerging technology, such as robotics and drones which require high-bay spaces for vertical lifting tests. Adapting existing spaces to accommodate this need would result in substantial modification of existing buildings that would also displace other uses, creating a cascading need for academic space, ultimately requiring the construction of new academic facilities. Rehabilitation would also require upgrade to air handling and ventilation systems and utility supply across multiple buildings.

Rehabilitating existing academic spaces also does not address parking shortages; this issue would continue to evidence where it currently does on post and may also occur in other new areas as academic uses would be redistributed to accommodate the CEAC uses. As Alternate A does not meet the purpose and need expressed for CEAC without creating more adverse impacts on the operations and mission of USMA and does not address the parking capacity need, this Alternate was not evaluated further.

Alternate B: Construct CEAC with Underground Parking Structure

Alternate B is the Proposed Action. This Alternate offers a state-of-the-art, centralized laboratory and collaborative learning space environment supporting the CEAC disciplines currently served by traditional learning spaces in Mahan Hall and Thayer Hall. This Alternate also provides additional parking in the form of an underground parking facility. By including the parking facility under the CEAC Building, this Alternate achieves the goals of the Purpose and Need without the additional excavation, stabilization, and visual impacts associated with an adjacent parking structure.

The Proposed Action necessitates the demolition of Quarters 5, 6, 7, and 8, Building #20, and the rock retaining wall adjacent to the sidewalk along Thayer Road. Quarters 5, 6, 7, and 8, Building #20, and the wall were preserved in the MPAC Preferred Alternative. As a result, engineering options were investigated to determine whether the CEAC could be accommodated in the footprint of the MPAC and whether it was feasible to relocate the Quarters or incorporate them into the CEAC program. These Alternates to avoid adverse effects on the NHLD included the following:

• Alternate B1: Accommodate CEAC in the MPAC Footprint: The MPAC building Preferred Alternative was proposed to be a six-story structure combining academic spaces and administrative uses. A parking structure was not proposed, and neither was mitigation for surface parking eliminated as a result of the development of the MPAC building, although it was acknowledged that mitigation may be necessary. The MPAC Supplemental Environmental Assessment depicted the site plan of the MPAC Preferred Alternative, illustrating the footprint of the building within the site of the Central Apartments without disturbance to Quarters 5, 6, 7, and 8.

The MPAC was conceptual and did not include site engineering data developed to the level of that prepared for the CEAC project. The CEAC analysis indicated that the grading activity for the MPAC building and rock cut for the access driveway to MPAC would have resulted in impacts to Quarters 5 and 6, and potentially Quarters 7. As a result, although the MPAC SEA presented the Preferred Alternative as one that preserved all four buildings, the reality is that Quarters 5, 6, 4 | P a g e and possibly 7 would have been found not to have been preserved once preliminary engineering had advanced the MPAC excavation and site grading plan. Consequently, confining the CEAC building to the footprint of the MPAC building would not result in the preservation of Quarters 5 and 6, would possibly affect Quarters 7. This Alternate was not selected to advance.

• Alternate B2: Develop CEAC in Another Location: The Jefferson Hall FEIS and the MPAC SEA both analyze potential locations for new academic buildings within the Central Zone. The subject site was determined in these prior analyses to be optimal for the location of the MPAC, and consequently the CEAC. As no other alternative exists to construct the CEAC within the Central Zone without impact to existing Barracks, academic buildings, or significant cultural resources, such as The Plain and Trophy Point, this Alternate was not pursued further.

• Alternate B3: Incorporate the Quarters into the CEAC Program: The space requirements and building systems necessary to accommodate the state-of-the-art facilities planned for CEAC would not be feasible in the existing Quarters buildings without substantial interior and exterior modification to the buildings. Rearrangement of interior spaces, including the removal of walls, would be necessary, and improvements to the exterior for interior access, security and ATFP would also be required. These changes would significantly affect the historic integrity of the Quarters. The Quarters, as separate, unconnected structures, would not meet the need for large collaborate capstone spaces or high-bay laboratories involving the use of a crane for heavy material lifts and movement, and fail to provide a singular, centralized location where engineering sciences would benefit from cross-discipline collaboration. A new building would still be required, as would the provision of additional parking space, either in the form of a parking structure or surface parking. As the incorporation of the Quarters into the CEAC program would significantly affect their historic integrity while failing to meet the purpose and need for the CEAC building and result in greater construction and long-term maintenance impacts, this Alternate was not advanced.

• Alternate B4: Relocate the Quarters: Relocating historic structures is complex and costly, and not all historic buildings are structurally strong enough to withstand the process of relocation without significant damage. In this instance, Quarters 8, which is condemned for structural issues associated with the foundation, would likely not tolerate the relocation process.

The additional consideration for moving the Quarters is their role as contributing resources to the West Point NHLD. To reduce the impact on the NHLD, the Quarters would need to be relocated within the designated boundaries of the District without adversely affecting another historic resource or otherwise compromising the District’s continuity. The NHLD is densely developed with historic structures and spaces that have established functional and visual relationships to each other. Available land within the District that is itself not an element of the district is extremely limited and there are no suitable locations that would accommodate the placement of the Quarters, either individually or as a group, or to accommodate their use either

5 | P a g e as quarters or other functions. As the costs, physical and logistical uncertainties, and likely secondary impacts to the NHLD and viewsheds may result from this Alternate, it was not advanced.

Alternate C: Construct CEAC with Adjacent Parking Structure

Alternate C proposes to construct the CEAC Building as described in the Proposed Action, but with the parking structure adjacent to the building instead of beneath it. The CEAC building would remain a 4-story building with pedestrian connectors to Mahan Hall and Building 606.

In addition to the grading required to develop the access road to the CEAC and parking structure, the creation of the building pad for both the CEAC and the parking structure would require extensive excavation of the hillside and subsequent stabilization and long-term erosion management. Concept design engineering estimates indicated that the adjacent parking structure would require approximately 50,000 cubic yards more excavation than an underground structure. The additional excavation and the stabilization measures increased environmental impacts, the cost of the project, and resulted in greater visual impacts.

Alternate C would not provide any advantage over the Proposed Action (Alternate B), and would result in greater geotechnical, stormwater management, environmental and visual impacts on account of the additional area to be excavated and stabilized to accommodate the parking structure. As Alternate C results in more impacts to achieve the same end result as the Proposed Action, this Alternate was dismissed from further evaluation.

III. ANTICIPATED ENVIRONMENTAL EFFECTS

Potential environmental impact issues related to the Proposed Action including mitigation measures that would be implemented to minimize or eliminate impacts are summarized below:

Air Quality

• A Federal General Conformity Analysis and Record of Non-Applicability (RONA) was performed to assess the potential temporary air quality impacts associated with the development of the CEAC building and the parking structure. The RONA is found in Appendix D of the Supplemental Environmental Assessment. The analysis concluded that while construction year 1 activities generate the most criteria pollutants as a result of the required rock removal by truck to an off-site facility, the construction phase emissions do not exceed de minimis levels for pollutants.

During construction years 2 through 4, the temporary construction emissions are well below the minimums for de minimis. No additional mitigation is required.

• The RONA was also performed to assess air quality impacts associated with the operation/use of the CEAC building post-construction. The assessment determined that the operation phase emissions do not exceed de minimis levels for pollutants.

• A passive radon management system is included in the design of the CEAC building. Radon levels will be monitored, and should radon concentrations exceed the safe limits (4.0 pCi/L), an active

6 | P a g e radon management system will be installed. The system will be designed, installed, and operated in accordance with AR 420-1.

Geology

• Site preparation for the CEAC Building and parking structure will require excavation of approximately 345,000 cubic yards of rock and a 70-foot rock cut. To secure the slope and prevent erosion and rock fall, both rock bolts and rock fall prevention netting are proposed.

• All excess soil will be sampled in accordance with the requirements of 6 NYCRR 360.13 prior to being removed from the site for disposal.

• Implementation of a Stormwater Pollution Prevention Plan (SWPPP) and an Erosion and Sediment Control plan (E&SC) will prevent erosion and degradation of area waterways.

• To mitigate the potential for seismic impacts, the CEAC would be constructed in accordance with the Uniform Building Code, the Provisions of the National Earthquake Hazards Reduction Program (NEHRP), United Facilities Criteria (UFC) 3-310-04 “Seismic Design for Buildings”, ICSSC RP6/NISTIR 6762 “Standards of Seismic Safety for Existing Federally Owned and Leased Buildings”, and ASCE/SEI 31-03.

Land Use

• The CEAC is consistent with existing land uses and adopted plans and programs. The building will be developed using context-sensitive design to harmonize the new structure with the appearance of the existing academic and residential buildings in the Cadet Zone.

• The replacement of the existing Quarters 5, 6, 7, and 8 with the CEAC structure represents a visual change; however, Quarters 8 is condemned and all are out of scale and character with the large neo-gothic structures of granite and brick comprising the Cadet Zone. The replacement use is consistent with the uses in the Cadet Zone.

• The residents of Quarters 5, 6, and 7 will be relocated by the Government, according to USAG procedures.

Water Resources

• No mitigation is required for groundwater, flood zones, or wetlands, as none of these resources are present in the project area to be directly affected by the project.

• Demolition activity associated with Quarters 5, 6, 7, and 8 and the required excavation will occupy more than one acre in area; therefore, a Stormwater Pollution Prevention Plan (SWPPP) and an Erosion and Sediment Control Plan (E&SC Plan) developed in accordance with local, state, and federal regulations will be required to prevent the movement of soil from the site into receiving waterways.

• CEAC represents a relocation of existing uses, not a net increase in uses or an increase in USMA population that would generate wastewater to be treated at the existing wastewater treatment plant. Any incremental additional wastewater generated by CEAC would be accommodated by the additional capacity of the proposed replacement Target Hill Water Treatment Plant.

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• The stormwater management improvements will be designed in accordance with Section 438 of the Energy Independence and Security Act (EISA) and New York State Department of Environmental Conservation (NYSDEC) Stormwater Management Design Manual. To meet the water quality requirement for DEC and EISA, the design will utilize green infrastructure practices and alternative methods to treat the entire volume of run-off produced from the 90th and 95th percentile storm event respectively.

• Storm piping will direct runoff into either a bioretention facility or stormfilter water quality structure, and then into an underground detention area. The detention area, located at the southeast corner of the CEAC Building below a bituminous pavement “drop-off” area, provides an area large enough for approximately 1,400 LF of 60” diameter solid wall HDPE pipe for stormwater detention, prior to discharge into the Hudson River.

Threatened and Endangered Species

• Threatened and/or Endangered Species are not known to inhabit the project area; however, arboreal species, such as the Northern Long-Eared Bat may occupy the area temporarily during their active period. Tree removal will likely be restricted during the pup season, June 1 to July 31.

• USMA is a party to the IMCOM Programmatic Agreement regarding the management of threatened and endangered species. Management of any sensitive species encountered within the CEAC site during construction or operation of the facility will conform to the procedures outlined in the IMCOM Programmatic Agreement.

Cultural Resources

• There will be no effect to archaeological resources as a part of this project.

• The Proposed Action would require the demolition of Quarters 5, 6, 7, and 8, Building 20 and the rock retaining wall along the west side of Thayer Road. The Proposed Action would constitute an adverse effect on the historic quarters. The USAG and the New York State Historic Preservation Office determined the USAG will rehabilitate the Ordnance Compound (Buildings 671, 671 A, 637, 635A, and 635B) and provide updated West Point geospatial data for cultural resources for inclusion in the New York Cultural Resources Information System.

• The placement of the building at the edge of the Central Zone of the Cadet Area and within the middle of the NHLD requires that the building design is sympathetic to the adjacent historic structures within the NHLD. The building façade utilizes aspects of the West Point Gothic aesthetic. The building will be clad in gray granite and limestone as well as feature multi-paned windows on all floors. The building and bridge design would not have an adverse effect on the

NHLD.

Noise

• Noise impacts are associated with the construction phase, which will require blasting and the use of heavy construction equipment, including trucks delivering construction material and removing excavated material from the site.

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• USAG will coordinate with USMA regarding academic activities, such as final exams. Blasting activity and other noise-generating construction procedures, such as drilling and pavement removal, will be scheduled around sensitive times in the academic calendar.

• The haul route within USMA for removal of excavated material will be coordinated with USMA administration to designate a route and schedule with the least potential for resulting in noise impacts on adjacent uses.

• During operation, the CEAC would not generate more noise than any other academic building on the USMA campus, with noise confined to automobiles, delivery trucks, and the operation of air-handling units on the roof. The future noise environment is anticipated to be an improvement over existing, as well, as in the present condition, the Central Apartments site is used for construction staging. This area would be incorporated into the CEAC.

Environmental Justice (EJ)

• The project will not result in negative or adverse impacts to EJ populations within or nearby the project site.

• The goals of the US Army as they relate to the development of the CEAC represent a national benefit or improvement for EJ communities. One of USMA’s goals is the increased recruitment of minority cadets who will receive career skills training applicable in both military and civilian service, improving earning potential and career opportunities for historically disadvantaged populations.

Energy

• The new building systems are expected to incorporate the objectives of the USAG-WP’s net zero energy installation initiative (Army Directive 2014-02)35. In addition, the new Operations/Maintenance Building is expected to be Leadership in Energy and Environmental Design (LEED) Silver certifiable.

• The building envelope has been designed to exceed the International Energy Conservation Code (IECC) and ASHRAE minimums by 20 to 30%. This includes window and skylight shading and conduction values as well as wall and roof insulation values.

• Energy savings were calculated for both LEED and EPAct. Using 30% design data, the calculations found a 16.2% cost savings under LEED and a 44.4% cost savings under EPAct.

• USMA DPW and City Light and Power (CLP) have identified that the new, private energy provider (CLP) has capacity to serve USMA with the addition of the CEAC building, without placing additional strain on the existing electric grid.

Hazardous Materials

• Hazardous materials investigation conducted in 2017 found asbestos and lead-containing materials in Quarters 5, 6, and 7. An earlier investigation from 2007 notes that lead based paint was found on the exterior of Quarters 8 and has been encapsulated. The hazardous materials reports include requirements for the project construction specifications for protecting public health and the natural environment during the demolition process. Measures include the use of

9 | P a g e personnel certified to handle hazardous materials and adherence to all local, state, and federal laws, rules, regulations, and best management practices.

• USMA will obtain any licenses required to use or store hazardous materials for use within the CEAC building and adhere to the Hazardous Materials Management System (HMMS) regarding the use and disposal of these materials.

Traffic

• Vehicles waiting to enter the CEAC driveway could back-up onto Thayer Road, resulting in traffic delays within the Central Zone. The traffic study conducted for CEAC indicated that a security gate processing time of 14 seconds or less would be adequate to mitigate any potential queuing that would result in an adverse effect on circulation. Specifications should include the processing time requirement.

• No mitigation is required for the proposed parking structure. The structure mitigates an existing adverse condition (inadequate parking capacity) in a way that is not visually intrusive and also results in improved safety and reduced roadway and parking area maintenance in the winter.

Coastal Resources

• The Coastal Zone Consistency analysis conducted for the MPAC building, relative to Policy No.

24, which seeks to protect “Exceptional Scenic Areas” was updated. The MPAC, which was proposed to be six (6) stories, received a negative declaration, which determines that no adverse impact will occur to coastal resources as result of the action. As the CEAC building is proposed to be four (4) stories and therefore less visually intrusive, harmonized with the surrounding historic context, and all best management practices for water quality would be employed during the demolition of Quarters 5, 6, 7, and 8, a negative declaration was likewise considered appropriate. NY State Department of State concurred.

Aesthetics and Visual Resources

• The proposed CEAC would not result in adverse effect to the viewsheds of West Point, except for the visual loss of Quarters 5-8. Any visual impacts could be mitigated by the design of CEAC, which will create a distinct and visible gateway to the campus along its main roadway. The low profile of the CEAC will harmonize with the scale and massing of the existing Cadet Zone. The CEAC will not protrude above the “skyline” of the existing academic buildings and barracks along Thayer Walk and will not visually compete with the Cadet Chapel’s tower for visual prominence.

• Lighting design will comply with the United States Military Academy Design Guide, United States Army Garrison Engineering Planning Standards, and the Garrison Commander’s Guidelines for Outdoor Lighting at West Point. Adherence to these guidelines and policies will ensure that the views at night are not significantly impacted by light pollution.

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Utilities

• West Point DPW and West Point Network Enterprise Center (NEC) indicate that adequate capacity exists to provide the necessary utilities to CEAC. The building will also incorporate LEED features and elements compliant with the Army’s Net Zero initiative.

IV. PUBLIC INVOLVEMENT

The Draft SEA and this Finding of No Significant Impact were made available for public review at the following locations:

Town of Highlands 254 Main Street Highland Falls, NY 10928

Village of Highland Falls 303 Main Street Highland Falls, NY 10928

Highland Falls Public Library 298 Main Street Highland Falls, NY 10928

Town of Philipstown 238 Main Street Cold Spring, NY 10516

Julia L. Butterfield Memorial Library 10 Morris Avenue

The Alice Curtis Desmond & Hamilton Fish Library PO Box 265 Garrison, NY 10524

Village of Cold Spring 85 Main Street

Additionally, the Draft SEA and Finding of No Significant Impact were sent directly to Federal, State, and County involved agencies and other interested parties.

The Draft SEA was made available for the 30-day public review period. During the time period of April 22, 2019 through April 30, 2019, public notices were published in the Times Herald Record (Middletown, NY), Putnam County News, Cornwall Local (Cornwall, NY), News of the Highlands (Highland Falls, NY), and the United States Military Academy (USMA) Post Bulletin (USMA, West Point, NY) to notify interested persons and organizations of the availability of the Draft SEA for public review and comment.

Affidavits of publication are provided in Appendix L of the Final SEA. The deadline for public comment on this Proposed Action was May 22, 2019.

No comments were received during the public comment period. One comment letter submitted to USMA by the New York State Department of Environmental Conservation (NYSDEC) on June 24, 2019 confirmed the environmental findings regarding the management of habitats and stormwater, but also requested clarification of the heat input rating (BTUs) of the proposed boilers. This information was