5.0
CUMULATIVE
EFFECTS
5.0 CUMULATIVE EFFECTS
This section provides: 1) a definition of cumulative effects, 2) a description of past, present, and
reasonably foreseeable actions relevant to cumulative effects, 3) an assessment of the nature of interaction
of the proposed action with other actions, and 4) an evaluation of cumulative effects potentially resulting
from these interactions.
5.1 DEFINITION OF CUMULATIVE EFFECTS
Council on Environmental Quality (CEQ) regulations stipulate that the cumulative effects analysis within
an environmental assessment (EA) should consider the potential environmental impacts resulting from
“the incremental impacts of the action when added to other past, present, and reasonably foreseeable
future actions regardless of what agency or person undertakes such other actions” (40 Code of Federal
Regulations [CFR] 1508.7). Recent CEQ guidance in Considering Cumulative Effects under the National
Environmental Policy Act (CEQ 1997) affirms this requirement, stating that the first steps in assessing
cumulative effects involve defining the scope of the other actions and their interrelationship with the
proposed action. The scope must consider geographic and temporal overlaps among the proposed action
and other actions. It must also evaluate the nature of interactions among these actions.
Cumulative effects are most likely to arise when a relationship or synergism exists between a proposed
action and other actions expected to occur in a similar location or during a similar time period. Actions
overlapping with or in close proximity to the proposed action would be expected to have more potential
for a relationship than those more geographically separated. Similarly, actions that coincide, even
partially, in time would tend to offer a higher potential for cumulative effects.
To identify cumulative effects the analysis needs to address three fundamental questions:
5.1.1
1.
Does a relationship exist such that affected resource areas of the proposed action might
interact with the affected resource areas of past, present, or reasonably foreseeable actions?
2.
If one or more of the affected resource areas of the proposed action and another action could
be expected to interact, would the proposed action affect or be affected by impacts of the
other action?
3.
If such a relationship exists, then does an assessment reveal any potentially significant
impacts not identified when the proposed action is considered alone?
Scope of Cumulative Effects Analysis
The scope of the cumulative effects analysis involves both the geographic extent of the effects and the
time frame in which the effects could be expected to occur. For this EA, the region of influence (ROI)
delimits the geographic extent of the cumulative effects analysis. The ROI includes Moody Air Force
Base (AFB) and vicinity; the horizontal boundaries of the airspace used for training, and the airspace
environment of the five civilian airports proposed for T-6A aircraft transition training. The time frame
for cumulative effects centers on the timing of the proposed action (second quarter of fiscal year 2001
[FY01/2]) and would continue into the foreseeable future.
The scope of the cumulative effects analysis also involves identifying other relevant actions in the ROI.
Beyond determining that the geographic scope and time frame for the actions interrelate to the proposed
5.0 Cumulative Effects
5-1
T-6A Beddown EA
Final
action, the analysis employs the measure of “reasonably foreseeable” to include or exclude other actions.
For the purposes of this analysis, public documents prepared by federal, state, and local government
agencies form the primary sources of information regarding reasonably foreseeable actions. Documents
used to identify other actions included environmental impact statements (EISs), EAs, management plans,
land use plans, other National Environmental Policy Act (NEPA) studies, and economic and demographic
projections.
5.2 PAST, PRESENT, AND REASONABLY FORESEEABLE ACTIONS
Numerous other activities exist in the ROI. The activities described here are not completely inclusive, but
they do serve to highlight some major influences in the region and to provide perspective on the
contribution to any impacts generated by the proposed action.
5.2.1
Past Actions Relevant to the Proposed Action
Cecil Field Naval Air Station Closure. The U.S. Department of the Navy (Navy) prepared an EIS in
December 1997 that addressed the environmental issues associated with the realignment of F/A-18
aircraft (Navy 1998). As part of this realignment, Moody AFB was assigned operational control of the
Live Oak Military Operations Area (MOA). No significant environmental impacts to the airspace were
found to be created by this transfer of scheduling authority.
5.2.2
Present Actions Relevant to the Proposed Action
The following actions have been approved and are in various stages of implementation at Moody AFB.
•
Force Structure Actions. In 1998, the Air Force made the decision to implement the following force
structure changes at Moody AFB: 1) drawdown 24 A/OA-10 aircraft and 563 personnel, and
inactivate the 70th Fighter Squadron (70 FS); 2) beddown an Introduction to Fighter Fundamentals
(IFF) pilot training program, its 57 T-38 aircraft and 408 personnel, and build and renovate facilities
required to accommodate the IFF program; and 3) beddown 6 additional HH-60 helicopters and 168
personnel into the 41st Rescue Squadron (41 RQS). An EA was prepared to assess the force structure
actions, and a Finding of No Significant Impact (FONSI) was signed on September 23, 1998 (Air
Force 1998a).
The findings of the EA included no significant impacts to any identified resource area. While
implementation of the action would result in long-term increases of mobile source emissions, these
increases would not produce long-term air quality degradation. Although noise levels in the
immediate vicinity of the base would increase over baseline levels, expansion of noise contours
would occur in predominantly unpopulated areas. Noise levels under the airspace areas would not
change significantly from conditions present at the time of the EA. Aircraft overflights would be of
short duration and would not significantly affect visual or recreational settings. Hazardous waste
generation on base would increase due to the addition of T-38 aircraft and HH-60 helicopters, but this
increase would be controlled and managed through existing hazardous waste management policies
and procedures. No hazardous wastes would be generated at the ranges or beneath associated
airspace areas. Geological resources, water resources, biological resources, and cultural resources
would not be significantly impacted. Construction activities would occur only within previously
developed areas on base (Air Force 1998a).
5-2
5.0 Cumulative Effects
T-6A Beddown EA
Final
Ground disturbance off base would be limited to Grand Bay Range, which is currently approved for
munitions training. Wildlife occurring under the Military Training Routes (MTRs), MOAs, and the
Moody Low Altitude Tactical Navigation (LATN) area is already subject to noise from military
aircraft and would not be adversely affected. Base personnel would increase by 14 people, and
existing housing in the region would accommodate these personnel and associated dependents.
Sufficient infrastructure and service capacity, including roadway capacity, exists in the ROI to
accommodate potential growth resulting from implementation of the force structure actions. Regional
economic activity would increase slightly as a result of the proposed action (Air Force 1998a). No
present actions relative to the proposed action are ongoing at Moody AFB or in the surrounding
vicinity. The impacts of this action are reflected in the baseline conditions of this EA.
•
Temporary Use of AT-38Bs with BDU-33s. The Air Force proposed to provide temporary
(approximately 12 months) stationing of AT-38Bs at Moody AFB in order to conduct IFF training.
Approximately 9,900 inert bomb dummy units (BDU)-33 practice bombs would be used annually at
Grand Bay Range. A Categorical Exclusion (CATEX) was approved for the AT-38B action (Air
Force 1999l).
•
Air Combat Command Air Control Squadron Action. The purpose of this action is to relocate the 71st
Air Control Squadron (71 ACS) from Moody AFB due to proposed mission changes and the need to
alleviate the high stress levels on ACSs. Beginning in FY00/4, this action would result in the loss of
136 manpower authorizations, approximately 80 vehicles, and other associated equipment. This
action was approved by a CATEX (Air Force 1999d). The results of this action are reflected in the
baseline conditions of this EA.
•
State Route 125/Bemiss Road. The Georgia Department of Transportation (Georgia DOT) proposed
to widen Bemiss Road (State Route 125) along an 8.8 mile stretch from Valdosta to just north of the
Moody AFB boundary. The improvement project consists primarily of separating the existing fourlane road with a 20-foot wide, raised grass median. Left turn lanes would be constructed in the
median, including lanes providing access to the base. According to Georgia DOT, the accident rate
on this roadway is 67 percent higher than the statewide average. A CATEX was approved for this
project (Georgia DOT 1997) and the Air Force issued a Finding of No Practicable Alternative
(FONPA) (Air Force 1998b). The results of this action are reflected in the baseline conditions of this
EA.
•
Base Recovery After Attack (BRAAT) Strip Construction at Moody AFB. Moody AFB proposed to
construct a new BRAAT strip adjacent to Crash Trail 1 and use the BRAAT strip for training
purposes on a routine basis. The proposed BRAAT strip would be about 150 feet wide and 1,000 feet
long (approximately 3.5 acres) sited parallel and immediately adjacent to Crash Trail 1. The BRAAT
strip would be paved with asphalt, and a 30- by 30-foot concrete square would be included at the
center of one end of the asphalt strip. Training on the BRAAT strip would consist of Rapid Runway
Repair training conducted once per month for a maximum of 2 days during daylight hours.
Approximately 30 personnel would participate in the monthly training activities. An EA was
prepared to assess this action, and a FONSI was signed on June 17, 1999 (Air Force 1999m).
•
Compost Pad Construction at Moody AFB. Moody AFB proposed to construct a 200- by 200-foot
concrete compost pad to enhance the composting of vegetation removed during landscaping activities.
Vegetation is currently disposed of in approved landfills. By creating a compost area, the vegetation
5.0 Cumulative Effects
5-3
T-6A Beddown EA
Final
can be composted and re-used in landscaping operations, thereby reducing the amount of refuse being
placed in the landfills. The compost pad would be used daily for the disposal of vegetation removed
during landscaping activities on the installation. An EA was prepared to assess this action and a
FONSI was signed on July 12, 1999 (Air Force 1999n).
•
820th Security Forces Group (820 SFG) Move to Moody AFB. The purpose of this action is to
provide trained and equipped security forces personnel at Moody AFB to better support Combat Air
Forces. This move would locate 15 personnel and approximately 25 vehicles to the base beginning in
FY00/1. The move is in anticipation of the beddown of the full 820 SFG at a later date (see next
section, Reasonably Foreseeable Actions at Moody AFB). This proposal was approved by a CATEX
(Air Force 1999c). The results of this action have been incorporated into the baseline conditions of
this EA.
•
Drawdown of F-16 Aircraft. The Air Force is planning force structure changes to streamline fighter
squadron operations. Beginning in FY01, Moody AFB would lose 36 F-16 Block 40 Primary
Aircraft Inventory (PAI) aircraft and approximately 1,259 military manpower authorizations
associated with those aircraft. This action would primarily affect the airfield and airspace
environment (reductions in jet noise and decreases in air pollutants) and would also result in a
temporary decrease in economic activity in the local community due to the lost manpower
authorizations (Air Force 1999a). The results of this action are reflected in the baseline conditions of
this EA.
5.2.3
Reasonably Foreseeable Actions at Moody AFB (Federal Actions)
The following proposals are currently under consideration by the Air Force. Separate NEPA analysis of
each action would be conducted prior to implementation of these proposed actions.
•
Beddown of the 820th Security Forces Group. In accordance with the FY99 Force Structure
Announcement, the 820 SFG would be located at Moody AFB. Over 600 personnel authorizations
would be assigned to the base. The mission of the 820 SFG is to provide trained, equipped, and
deployable force protection to meet Air Force requirements in support of Combat Air Forces.
Renovations to existing buildings would occur as part of this proposed action. In addition, the
Bemiss Field area would be used for field training activities on a year-round basis.
5.2.4
Other Reasonably Foreseeable Actions near Moody AFB (Non-Federal Actions)
Levi-Strauss & Company, the sixth largest employer in Lowndes County, recently announced the closure
of its Valdosta facility, resulting in the loss of 837 local jobs. The loss of these jobs would likely be
offset by the otherwise steady industrial and commercial growth in Lowndes County. For example,
Lowe’s Distribution Center is expanding operations and will employ more than 350 people, and Sterling
Pulp Chemicals recently completed a new facility which will employ 25 people (Valdostaga.com 1999).
5.2.5
5.2.5.1
•
5-4
Other Federal Actions
AIR FORCE
Search and Rescue Training by HC-130 Aircraft and HH-60 Helicopters. To support search and
rescue training by the 41st and 71st Rescue Squadrons, the Air Force would establish a water training
area in the Gulf of Mexico, create three helicopter aerial refueling tracks for training and operational
5.0 Cumulative Effects
T-6A Beddown EA
Final
refueling with HC-130 aircraft, and use an existing airfield in Florida for helicopter aircrew swaps to
provide enhanced aircrew training capability in the water training area. There would be no
requirement for new facility construction or renovation or additional personnel or aircraft for Moodybased squadrons.
•
Beddown of F-22 at Tyndall AFB. Another upcoming Air Force project involves the deployment of
F-22 fighter jet aircraft, which is currently in the test and validation stage. The F-22s may eventually
replace the F-15s and would be involved in training in areas near Tyndall AFB. These areas include
the use of airspace also proposed for use by the T-6As: Tyndall B, C, and H MOAs which overlie
VR-1065; Live Oak MOA; and Moody 3 MOA. Cumulative impacts of the F-22s would be primarily
due to differences between the noise characterizations of the F-22 and F-15. The time frame for this
action is the next 5 to 10 years.
5.2.5.2
FEDERAL AVIATION ADMINISTRATION
The Federal Aviation Administration (FAA) has a major proposal to modernize and reengineer the
National Airspace Architecture. The National Airspace Architecture describes changes in
communications, navigation, surveillance, automation tools, avionics, and computers/networks. These
changes will affect flight operations over Georgia, Florida, and the Gulf of Mexico. The FAA is planning
to redesign Air Route Traffic Control Centers (ARTCCs) to accommodate air traffic in the Jacksonville,
Miami, and Houston ARTCCs. None of these changes would affect the airspace proposed for use by
T-6A and T-38 aircraft.
While this FAA initiative is still in the planning stages, the cumulative effects to Air Force operations and
airspace management, particularly with respect to implementation of the proposed action analyzed in this
EA, remain unknown at this time. No changes in airspace boundaries are planned.
5.3 CUMULATIVE EFFECTS ANALYSIS
The following discussion describes how the impacts of other past, present, and reasonably foreseeable
actions might be affected by those resulting from the proposed action at Moody AFB, and whether such
relationships would result in potentially significant impacts not identified when the proposed action is
considered alone.
5.3.1
Cecil Field Naval Air Station Closure
The realignment that assigned Moody AFB operational control of the Live Oak MOA allows Moody AFB
the operational control of this airspace. No significant environmental impacts to the airspace were found
to be created by this transfer of scheduling activity.
5.3.2
Force Structure Actions
As analyzed in previous environmental documentation (Air Force 1998a), implementation of force
structure changes at Moody AFB did not result in significant environmental impacts. Compared to
baseline conditions, impacts to noise would not significantly increase with implementation of the
proposed action. Given that the proposed action would not result in significant noise impacts or other
significant impacts to environmental resources, the cumulative impacts of projected activities associated
with force structure changes at Moody AFB would not be significant. Activities associated with the
current force structure actions are ongoing at Moody AFB and will continue into FY01.
5.0 Cumulative Effects
5-5
T-6A Beddown EA
5.3.3
Final
Temporary Use of AT-38Bs with BDU-33s
A CATEX was approved for the temporary beddown of AT-38Bs at Moody AFB. This action includes
weapons delivery training at Grand Bay Range with approximately 9,900 BDU-33s dropped annually (Air
Force 1999l). As stated in the CATEX, implementation of this action would not result in any significant
environmental impacts. This action, when combined with the proposed action, would not result in a
significant cumulative impact to any resource area. This action would occur in FY00/4 but would only
occur if the T-38Cs are not yet available.
5.3.4
ACC Air Control Squadron Action
A CATEX was approved for the relocation of 136 manpower authorizations and approximately 80
vehicles from Moody AFB (Air Force 1999d). As stated in the CATEX, implementation of this action
would not result in significant environmental impacts. This action, when combined with the proposed
action, would not result in a significant cumulative impact to any resource area. This action would occur
in FY00/4.
5.3.5
State Route 125/Bemiss Road
A CATEX was approved by the Georgia DOT and the Air Force issued a FONPA for the widening of
Bemiss Road (State Route 125) from Valdosta to just north of Moody AFB (Georgia DOT 1997, Air
Force 1998b). As stated in the CATEX, implementation of this action would not result in significant
environmental impacts. This action, when combined with the proposed action, would not result in a
significant cumulative impact on any resource area. The widening of Bemiss Road could improve the
traffic circulation conditions for personnel entering and departing Moody AFB. Specific dates for this
action have not yet been established.
5.3.6
BRAAT Strip Construction
The proposed construction and use of a new BRAAT strip would result in the paving of approximately
3.5 acres and the addition of training activities once per month to this area of Moody AFB (Air Force
1999m). Moody AFB can easily accommodate this additional limited volume of activity. The magnitude
of the action is minimal, and proposed construction associated with the BRAAT strip would affect a very
specific area. Given that the proposed action would have a minimal effect within the base, the combined
impacts of both actions would not result in significant cumulative impacts to any resource area.
5.3.7
Compost Pad Construction
The proposed construction of a 200- by 200-foot concrete compost pad on Moody AFB would result in
the paving of approximately 1 acre (Air Force 1999n). Given the small project size and minimal
environmental effects, the combined impact of the proposed T-6A beddown would not result in
significant cumulative impacts to any resource area.
5.3.8
Beddown of the 820 SFG
The proposed beddown of the 820 SFG would involve field and classroom training at Moody AFB and
would not involve any airspace or airfield operations. Although not fully analyzed, it is anticipated that
the construction and renovation projects, the use of the Bemiss Field area for field training activities, or
5-6
5.0 Cumulative Effects
T-6A Beddown EA
Final
the addition of the 620 personnel associated with the 820 SFG beddown would not result in significant
impacts in any resource area, individually or cumulatively.
5.3.9
F-16 Drawdown
The proposed deactivation of the 68 FS and 69 FS would result in the loss of approximately 1,259
military manpower authorizations (Air Force 1999a). Potential reductions in earnings, employment, and
community activity that would result from implementation of the proposed F-16 drawdown would be
partially offset with implementation of the beddown of the T-6A and associated ground-based training
activities due to the increase in personnel and associated economic impact. The combined impact of both
actions would not result in significant cumulative impacts to any resource area.
5.4 SUMMARY OF CUMULATIVE EFFECTS
In summary, none of the projected impacts of the proposed action are individually significant. The
incremental contribution of impacts of the proposed action, when considered in combination with other
past, present, and reasonably foreseeable actions would not be significant. Overall impacts to
socioeconomics would be beneficial with implementation of the proposed action. Implementation of the
beddown of T-6A aircraft and the associated ground-based training activities at Moody AFB would help
restore manpower authorizations that would be lost as a result of the drawdown of the F-16 squadrons and
would serve as an economic stimulus to the local community.
As shown in Figure 5.1-1, the cumulative effects of the proposed and reasonably foreseeable actions at
Moody AFB would create an overall balance in the total number of personnel assigned to Moody AFB.
Over the timeframe from FY99/4 to FY02/1, total personnel numbers would vary from 3,306 to 4,589.
However, final projected personnel numbers would stabilize to approximately 4,372 by FY01/4 if all
actions were implemented.
5.0 Cumulative Effects
5-7
3,000
Enlisted
Total
Total
Enlisted
Enlisted
Total
Total
Enlisted
4,000
Officer
Enlisted
Civilian
Contractor
TOTAL
Contractor
Civilian
Officer
Contractor
Civilian
Officer
Contractor
,,,
,,,
,,,
Current Conditions
0
Civilian
Civilian
Contractor
1,000
Officer
2,000
Officer
MANPOWER AUTHORIZATIONS
5,000
,,,
,,,
,,,,
,,,,,,,
F-16 Drawdown
,,
,,
,,,,
,,,,,,
820 SFG Beddown
,,
,,,,
,,
,,,,
,,,,
,,
T-6A Beddown
(FY99/4)
(FY01/2)
(FY01/3)
(FY02/1)
484
3,710
395
0
4,589
435
2,331
396
144
3,306
465
2,917
400
144
3,926
751
2,978
403
240
4,372
Total
140
120
HC-130
HH-60
A/OA-10
F-16
T-38
T-6
TOTAL
(FY99/4)
F-16 Drawdown
(FY01/2)
9
14
12
36
0
0
71
9
14
0
0
54
0
77
F-16
HH-60
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
A/OA-10
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
,,,,
HC-130
F-16
A/OA-10
HH-60
HC-130
T-6
T-38
T-38
0
A/OA-10
20
,,,
,,,
,,,
,,,
,,,
,,,
Current Conditions
HH-60
40
,,
,,
T-6
F-16
60
T-6
80
T-38
Total
Total
100
HC-130
PRIMARY AIRCRAFT INVENTORY (PAI)
Manpower Authorizations
T-6A Beddown
(FY02/1)
9
14
0
0
54
38
115
Primary Aircraft Inventory
Cumulative Effects: Manpower Authorizations and Primary Aircraft Inventory
5-8
Figure 5.1-1
5.0 Cumulative Effects