PUBLIC DRAFT

ENVIRONMENTAL ASSESSMENT

OF THE PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO

DEPARTMENT OF VETERANS AFFAIRS 425 I STREET, NW WASHINGTON, DC 20001

PREPARED BY: TTL ASSOCIATES, INC.

JULY 18, 2019 DEPARTMENT OF VETERANS AFFAIRS EXECUTIVE SUMMARY

EXECUTIVE SUMMARY

This Environmental Assessment (EA) has been prepared to identify, analyze, and document the potential physical, environmental, cultural, and socioeconomic impacts associated with the Department of Veterans Affairs (VA’s) proposed establishment of an approximately 75,645 net useable square-foot (NUSF) Outpatient Clinic (OPC) in Larimer County, Colorado. Preparation of this EA is required in accordance with the National Environmental Policy Act of 1969 ([NEPA]; 42 United States Code [USC] 4321 et seq.), the President's Council on Environmental Quality (CEQ) Regulations Implementing the Procedural Provisions of NEPA (40 Code of Federal Regulations [CFR] 1500-1508), and Environmental Effects of the Department of Veterans Affairs Actions (38 CFR Part 26). This EA has also been prepared in accordance with VA NEPA Interim Guidance for Projects dated 30 September 2010.

PROPOSED ACTION

VA’s Proposed Action is to establish an approximately 75,645 NUSF, one or two-story OPC, including required parking (approximately 550 surface parking spaces), and other required site amenities and improvements in northern Colorado (Larimer County).

The Proposed Action would consolidate and replace the existing undersized leased Fort Collins Multi-Specialty Outpatient Clinic (MSOC) and Loveland Community Based Outpatient Clinic (CBOC) with a new, appropriately sized, integrated, state-of-the-art, health care facility. VA would select a developer (VA developer), who would construct the proposed OPC for VA on a build-to- suit basis, and then lease it to VA for up to 20 years.

PURPOSE AND NEED

The purpose of the Proposed Action is to provide consolidated and expanded outpatient health care services to Veterans in the northern Colorado area in an integrated, right-sized facility. The Proposed Action would provide a centralized, appropriately sized facility for VA to expand its primary care, mental health care, and specialty care services to Veterans in the region. The Proposed Action would allow VA to provide timely access to state-of-the-art, integrated health care services in a modern, properly sized facility to meet current and projected workloads.

The Proposed Action is needed to address current and future projected health care utilization, wait time, and space gaps, and operational inefficiencies that were identified through the VA Strategic Capital Investment Planning process. The Fort Collins MSOC (approximately 10,000 NUSF) and Loveland CBOC (approximately 23,000 NUSF) are undersized and are insufficient to meet the current and future health care needs of area Veterans. In addition, operating separate outpatient clinics in the area creates operational inefficiencies, poorly integrated services, and increases costs.

The Proposed Action would result in improved health care for northern Colorado area Veterans by providing expanded outpatient services in a new, appropriately sized, centralized, modern facility.

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ALTERNATIVES

This EA examines in depth five alternatives: the implementation of the Proposed Action at one of four Action Alternative sites (Sites 1-4) and the No Action Alternative.

Site 1 – 4875 Byrd Drive (Loveland): Site 1 consists of approximately 15 acres of unimproved, agricultural land. Site 1 has been agricultural land since at least the 1940s. The one-story OPC building and associated parking areas would encompass the majority of the site, with the building in the western portion of the site and majority of the parking in the eastern portion of the site. Access would be provided by an access road through an easement from Byrd Drive.

Site 2 – Southwest Corner of East County Road 32 (State Route 392) and Southwest Frontage Road (Fort Collins): Site 2 consists of one approximately 24-acre parcel of unimproved land. The eastern-central portion of the parcel contains wetlands that appear to be associated with off-site Fossil Creek Reservoir. The OPC development would be located on the western portion of the parcel (approximately 15 acres), west of the wetlands. Site 2 has been undeveloped with areas of disturbed land and some agricultural use since at least the 1940s. The one-story OPC building and associated parking areas would encompass the majority of the western portion of the site. Primary and secondary access would be from East County Road 32 (State Route 392/Carpenter Road).

Site 3 – Northwest Corner of Ronald Reagan Boulevard and Trade Street (Johnstown): Site 3 consists of approximately 10.4 acres of undeveloped, mostly grassy land. Site 3 was agricultural land from at least the 1940s until 2004, with Farmers Ditch (an irrigation ditch) crossing the central portion of the site. In 2005, Farmers Ditch was rerouted below grade along the northern site boundary, infrastructure was added, and the site area was graded in anticipation of development. Site 3 has been vacant grassy land since 2005. The two-story OPC building and associated parking areas would encompass the majority of the site. Primary access would be from Union Street from the north and Ronald Reagan Boulevard from the south. Secondary access would from Trade Street from the east.

Site 4 – Centerra Parkway (Loveland): Site 4 consists of approximately 15 acres of unimproved, agricultural land. Site 4 has been agricultural land since at least the 1940s. The one-story OPC building and associated parking areas would encompass the majority of the site. Access would be provided from a proposed road and a proposed drive from Centerra Parkway.

With any of the Action Alternatives, the VA developer would build and own the OPC and would be responsible to design and construct the facility in compliance with VA design requirements and applicable federal, state, and local regulations. The OPC would be a one to two-story, approximately 75,645 NUSF slab-on-grade structure with surrounding paved, surface-level parking lots (total of approximately 550 on-site parking spaces). The VA design requirements specify that the OPC development must meet a minimum rating of two Green Globes for new construction and sustainable interiors and the building is required to earn an Energy Star label. These VA contract design requirements ensure that the OPC would be sustainably developed. The facility would be leased and operated by VA.

DRAFT ENVIRONMENTAL ASSESSMENT E-2 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS EXECUTIVE SUMMARY

VA anticipates construction of the proposed OPC would begin in 2020 and that the OPC would open in 2022. The new OPC would provide primary care, mental health, and specialty care outpatient services to the area's Veterans. This function is currently provided by two existing VA leased facilities, the Fort Collins MSOC (2509 Research Boulevard, Fort Collins, Colorado) and the Loveland CBOC (5200 Hahns Peak Drive, Loveland, Colorado). VA would no longer lease or operate these facilities once the proposed OPC is open and the existing leases expire.

No Action Alternative

Under the No Action Alternative, the Proposed Action would not be implemented. VA would continue to provide primary care, mental health, and specialty health care services at the existing, undersized Fort Collins MSOC and Loveland CBOC. The Action Alternative sites would likely remain vacant for the near future and ultimately be developed by others for commercial use, consistent with local zoning. This alternative would limit VA’s ability to provide necessary health care services to U.S. Veterans in the region, and would not meet the purpose of or need for the Proposed Action. However, the No Action Alternative was retained to provide a comparative baseline analysis as required under CEQ Regulations.

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

The affected environment of the Action Alternative sites and their immediate surroundings, or the Region of Influence (ROI) of the Proposed Action, is discussed in Section 3 of this EA.

The five considered alternatives, the implementation of the Proposed Action at one of the four Action Alternative sites and the No Action Alternative, are evaluated in this EA to determine their potential direct or indirect impact(s) on the environmental, cultural, and socioeconomic aspects of the Proposed Action’s ROI. Technical areas evaluated in this EA include:

. Aesthetics . Socioeconomics . Air Quality . Community Services . Cultural Resources . Solid Waste and Hazardous Materials . Geology, Topography, and Soils . Transportation and Parking . Hydrology and Water Quality . Utilities . Wildlife and Habitat . Environmental Justice . Noise . Cumulative Impacts . Land Use . Potential for Generating Substantial . Floodplains, Wetlands, and Coastal Zone Controversy Management

Action Alternatives

The Action Alternatives would result in the impacts identified throughout Section 3 and summarized in Table 10. These include short-term and/or long-term potential adverse impacts to aesthetics (Sites 2 and 3), air quality, soils and geology, hydrology and water quality, wildlife and habitat, noise, wetlands (Site 2), solid waste and hazardous materials, transportation, and utilities. All of these impacts are less than significant and would be further reduced through careful coordination and implementation of best management practices (BMPs) and management measures, avoidance measures (for potential wildlife and wetlands impacts at Site 2), and compliance with regulatory requirements, as identified in Section 5.

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The Action Alternatives would result in beneficial short-term and long-term impacts to the local socioeconomic environment. Notably, a significant long-term beneficial effect to the health of U.S. Veterans in the region would occur should a new OPC be constructed at one of the Action Alternative sites.

No Action Alternative

Under the No Action Alternative, the Proposed Action would not be implemented and no adverse environmental effects would occur. No beneficial impacts attributable to the Proposed Action would occur and VA’s ability to provide sufficient, requisite health care services to the region's Veterans would be compromised.

AGENCY AND PUBLIC INVOLVEMENT

Agencies consulted for this EA include:

• U.S. Fish and Wildlife Service (USFWS) • U.S. Environmental Protection Agency • U.S. Army Corps of Engineers (USACE) • U.S. Department of Agriculture Natural Resource Conservation Service • Colorado Department of Natural Resources (CDNR) (various divisions) • Colorado Department of Public Health & Environment • Colorado Department of Transportation (CDOT) • Colorado State Forest Service • History Colorado Office of Archaeology and Historic Preservation (State Historic Preservation Office) • North Front Range Metropolitan Planning Organization • Larimer County (various departments) • City of Fort Collins (various departments) • Town of Johnstown (various departments) • City of Loveland (various departments)

Responses were received from USFWS, USACE, CDNR – Division of Water Resources, CDNR – Parks and Wildlife, CDOT, Larimer County Engineering Department, Fort Collins Community Development and Neighborhood Services Department, Fort Collins-Loveland Water District/South Fort Collins Sanitation District, Johnstown Planning and Development Department, Loveland Parks and Recreation Department, and Loveland Water and Power. Input provided by these agencies is summarized in Section 4. Agency information and comments have been incorporated into this EA, as and where appropriate. Copies of relevant correspondence can be found in Appendix A.

Six federally recognized Native American Tribes were identified as having possible ancestral ties to the Larimer County area. VA invited each of these Tribes to provide input regarding the Proposed Action. Tribal information and comments have been incorporated into this EA (Section 3.4). Tribal input is summarized in Section 4. Tribal correspondence is provided in Appendix B.

DRAFT ENVIRONMENTAL ASSESSMENT E-4 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS EXECUTIVE SUMMARY

VA will publish and distribute the Draft EA for a 30-day public comment period, as announced by a Notice of Availability published in a local newspaper of general circulation (Loveland Reporter- Herald). A copy of the Draft EA will be made available for public review at a local public library. VA will respond to public comments in the Final EA.

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TABLE OF CONTENTS

SECTION PAGE

EXECUTIVE SUMMARY ______1

SECTION 1: INTRODUCTION ______1 1.1 INTRODUCTION ______1 1.2 BACKGROUND ______1 1.3 PURPOSE AND NEED ______5 1.4 DECISION-MAKING ______5

SECTION 2: DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES ______6 2.1 INTRODUCTION ______6 2.2 PROPOSED ACTION ______6 2.3 ALTERNATIVES ANALYSIS ______6

SECTION 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ______16 3.1 INTRODUCTION ______16 3.2 AESTHETICS ______17 3.3 AIR QUALITY ______19 3.4 CULTURAL RESOURCES ______21 3.5 GEOLOGY AND SOILS ______23 3.6 HYDROLOGY AND WATER QUALITY ______28 3.7 WILDLIFE AND HABITAT ______32 3.8 NOISE ______36 3.9 LAND USE ______40 3.10 WETLANDS, FLOODPLAINS, AND COASTAL ZONE MANAGEMENT ______43 3.11 SOCIOECONOMICS ______51 3.12 COMMUNITY SERVICES ______54 3.13 SOLID AND HAZARDOUS MATERIALS ______55 3.14 TRANSPORTATION AND PARKING ______57 3.15 UTILITIES ______62 3.16 ENVIRONMENTAL JUSTICE ______64 3.17 CUMULATIVE IMPACTS ______65 3.18 POTENTIAL FOR GENERATING SUBSTANTIAL PUBLIC CONTROVERSY ______67

SECTION 4: PUBLIC INVOLVEMENT ______68 4.1 AGENCY COORDINATION ______68 4.2 NATIVE AMERICAN CONSULTATION ______72 4.3 PUBLIC REVIEW ______72

SECTION 5: MANAGEMENT AND MINIMIZATION MEASURES ______73

SECTION 6: SUMMARY AND CONCLUSIONS ______77

SECTION 7: LIST OF PREPARERS ______84

SECTION 8: REFERENCES CITED ______85

SECTION 9: LIST OF ACRONYMS AND ABBREVIATIONS ______90

DRAFT ENVIRONMENTAL ASSESSMENT i PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS INTRODUCTION

SECTION 10: AGENCIES AND INDIVIDUALS CONSULTED ______92

SECTION 11: LIST OF ENVIRONMENTAL PERMITS REQUIRED ______95 11.1 REGULATORY FRAMEWORK ______95 11.2 ENVIRONMENTAL PERMITS REQUIRED ______96

SECTION 12: GLOSSARY ______97

LIST OF TABLES

TABLE PAGE

TABLE 1 FEDERALLY LISTED SPECIES IN THE VICINITY OF THE ACTION ALTERNATIVE SITES _ 34

TABLE 2 PEAK NOISE LEVELS EXPECTED FROM TYPICAL CONSTRUCTION EQUIPMENT _____ 39

TABLE 3 DEMOGRAPHIC DATA FOR FORT COLLINS, LOVELAND, JOHNSTOWN, LARIMER COUNTY, AND COLORADO ______52

TABLE 4 REGIONAL INCOME FOR FORT COLLINS, LOVELAND, JOHNSTOWN, LARIMER COUNTY, AND COLORADO ______52

TABLE 5 SITE 1 AREA ROADWAYS ______58

TABLE 6 SITE 2 AREA ROADWAYS ______59

TABLE 7 SITE 3 AREA ROADWAYS ______59

TABLE 8 SITE 4 AREA ROADWAYS ______60

TABLE 9 BEST MANAGEMENT PRACTICES AND MINIMIZATION MEASURES INCORPORATED INTO THE PROPOSED ACTION ______73

TABLE 10 SUMMARY OF SITE CHARACTERISTICS AND POTENTIAL IMPACTS ASSOCIATED WITH THE PREFERRED ACTION ALTERNATIVE ______78

LIST OF FIGURES

FIGURE PAGE

FIGURE 1 REGIONAL LOCATION MAP ______3

FIGURE 2 VICINITY STREET MAP ______4

FIGURE 3 SITES 1 AND 2 - TOPOGRAPHIC MAP ______10

FIGURE 4 SITE 1 - AERIAL PHOTOGRAPH ______11

DRAFT ENVIRONMENTAL ASSESSMENT ii PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS INTRODUCTION

FIGURE 5 SITE 2 - AERIAL PHOTOGRAPH ______12

FIGURE 6 SITES 3 AND 4 - TOPOGRAPHIC MAP ______13

FIGURE 7 SITE 3 - AERIAL PHOTOGRAPH ______14

FIGURE 8 SITE 4 - AERIAL PHOTOGRAPH ______15

FIGURE 9 SITE SOILS MAPS ______26

FIGURE 10 SITE ZONING MAPS ______42

FIGURE 11 SITE 1 – FEDERAL AND STATE WETLANDS MAPS ______45

FIGURE 12 SITE 2 – FEDERAL AND STATE WETLANDS MAPS ______46

FIGURE 13 SITE 3 – FEDERAL AND STATE WETLANDS MAPS ______47

FIGURE 14 SITE 4 – FEDERAL AND STATE WETLANDS MAPS ______48

FIGURE 15 SITE FLOODPLAIN MAPS ______50

LIST OF APPENDICES

APPENDIX A – AGENCY CORRESPONDENCE

APPENDIX B – NATIVE AMERICAN TRIBE CORRESPONDENCE

APPENDIX C – PHOTOGRAPH LOGS

APPENDIX D – OTHER RELEVANT ENVIRONMENTAL DATA

APPENDIX E – PUBLIC NOTICES AND COMMENTS

DRAFT ENVIRONMENTAL ASSESSMENT iii PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS INTRODUCTION

SECTION 1: INTRODUCTION

1.1 Introduction

This Section provides the reader with necessary introductory and background information concerning the Proposed Action for proper analytical context; identifies the purpose of and need for the Proposed Action and the federal decision to be made.

This Environmental Assessment (EA) has been prepared as required in accordance with the National Environmental Policy Act of 1969 ([NEPA]; 42 United States Code [USC] 4321 et seq.), the President's Council on Environmental Quality (CEQ) Regulations Implementing the Procedural Provisions of NEPA (40 Code of Federal Regulations [CFR] 1500-1508), and Environmental Effects of the Department of Veterans Affairs Actions (38 CFR Part 26). This EA is required to determine if VA’s Proposed Action would have significant environmental impacts. Federal Agencies are required to consider the environmental and related social and economic effects of their proposed actions. This EA has been prepared in accordance with VA’s NEPA Interim Guidance for Projects (2010).

This EA has been prepared to identify, analyze, and document the potential physical, environmental, cultural, and socioeconomic impacts associated with the VA’s proposed construction and operation of:

. An approximately 75,645 net usable square-foot (NUSF) one to two-story, slab-on-grade Outpatient Clinic (OPC); . Associated parking (approximately 550 surface parking spaces); . Other required site improvements and amenities; and . Landscaped open space areas.

The facility would be established on one of four sites (Sites 1 through 4) in northern Colorado (Larimer County). Figures 1 and 2 depict the general locations of the four sites.

In accordance with the above regulations, this EA: allows for public input into the federal decision- making process; provides federal decision-makers with an understanding of potential environmental effects of their decisions, before making these decisions; identifies measures the federal decision-maker could implement to reduce potential environmental effects; and documents the NEPA process.

1.2 Background

The Cheyenne VA Health Care System is anchored by the Cheyenne VA Medical Center and includes four community clinics [including the current Fort Collins Multi-Specialty Outpatient Clinic (MSOC), Loveland Community Based Outpatient Clinic (CBOC), and clinics in Rawlins, Wyoming and Sidney, Nebraska, and four mobile clinics. The Cheyenne VA Health Care System serves approximately 70,000 Veterans living in the tri-state area of southeastern Wyoming, northeastern Colorado, and southwestern Nebraska.

DRAFT ENVIRONMENTAL ASSESSMENT 1 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS INTRODUCTION

The two existing leased VA clinics in northern Colorado, the Fort Collins MSOC (2509 Research Boulevard, Fort Collins) and the Loveland CBOC (5200 Hahns Peak Drive, Loveland), are undersized and insufficient to meet the current and future projected health care needs of area Veterans.

In fiscal year 2018, Congress authorized VA, under the Veterans Access, Choice, and Accountability Act, to establish a new, larger OPC in the northern Colorado area, which would replace the existing undersized Fort Collins MSOC and Loveland CBOC. The new facility would enhance VA outpatient services by closing space and utilization gaps identified in the VA Strategic Capital Investment Planning process and would reduce patient wait times. The new facility would integrate outpatient care delivery (primary, mental health, specialty care, and ancillary services) into an appropriately sized, centralized and efficient, state-of-the-art facility to meet the requirements of the VHA Health Care Uniform Benefits package.

DRAFT ENVIRONMENTAL ASSESSMENT 2 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS INTRODUCTION

CURRENT FORT COLLINS MSOC SITE 2 SITE 1 SITE 4

SITE 3

CURRENT LOVELAND CBOC

PREPARED FOR FIGURE 1 U.S. DEPARTMENT OF VETERANS AFFAIRS REGIONAL LOCATION MAP WASHINGTON, DC ENVIRONMENTAL ASSESSMENT PROPOSED OPC TTL PROJECT NO. LARIMER COUNTY, COLORADO 1801701

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SITE 2

BYRD DRIVE

E CROSS CENTERRA ROADS SITE 1 PARKWAY BOULEVARD

SITE 4

SITE 3

PREPARED FOR FIGURE 2 U.S. DEPARTMENT OF VETERANS AFFAIRS VICINITY STREET MAP WASHINGTON, DC ENVIRONMENTAL ASSESSMENT PROPOSED OPC TTL PROJECT NO. LARIMER COUNTY, COLORADO 1801701

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1.3 Purpose and Need

The purpose of the Proposed Action is to provide consolidated and expanded outpatient health care services to Veterans in the northern Colorado area in an integrated, right-sized facility. The Proposed Action would provide a centralized, appropriately sized facility for VA to expand its primary care, mental health care, and specialty care services to Veterans in the region. The Proposed Action would allow VA to provide timely access to state-of-the-art health care services in a modern, properly sized facility to meet current and projected workloads.

The Proposed Action is needed to address current and future projected health care utilization, wait time, and space gaps, and operational inefficiencies that were identified through the VA Strategic Capital Investment Planning process. The existing Fort Collins MSOC (approximately 10,000 NUSF) and Loveland CBOC (approximately 23,000 NUSF) are undersized and are insufficient to meet the current and future health care needs of area Veterans. In addition, operating separate outpatient clinics in the area creates operational inefficiencies, poorly integrated services, and increases costs.

The Proposed Action would result in improved health care for northern Colorado area Veterans by providing expanded outpatient services in a new, appropriately sized, modern facility.

1.4 Decision-Making

This EA has been prepared to identify, analyze, and document the potential environmental, cultural, and socioeconomic impacts associated with VA's proposed construction and operation of a new OPC in northern Colorado (Larimer County).

VA, as a federal agency, is required to incorporate environmental considerations into their decision-making process for the actions they propose to undertake. This is done in accordance with the regulations identified in Section 1.1.

In accordance with the above regulations, VA has prepared this EA. This EA allows for public input into the federal decision-making process; provides federal decision-makers with an understanding of potential environmental effects of their decisions before making these decisions; and documents the NEPA process.

Ultimately, VA will decide, in part based on the analysis presented in this EA and after having taken potential environmental, cultural, and socioeconomic effects into account, whether VA should implement the Proposed Action, and, as appropriate, carry out mitigation and management measures to reduce effects on the environment.

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SECTION 2: DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES

2.1 Introduction

This Section provides the reader with necessary information regarding the Proposed Action and its alternatives, including those that VA initially considered, but eliminated, and the reasons for eliminating them. The screening criteria and process developed and applied by VA to hone the number of viable sites are described, providing the reader with an understanding of VA’s rationale in ultimately analyzing four Action Alternatives in this EA.

2.2 Proposed Action

VA’s Proposed Action is to establish an approximately 75,645 NUSF, one or two-story OPC, including required parking (approximately 550 surface parking spaces), and other required site amenities and improvements in northern Colorado (Larimer County).

VA established the size of the facility and the land area required for the proposed OPC based on the number of Veterans currently receiving health care services at the existing Fort Collins MSOC and Loveland CBOC and those Veterans forecasted to require such services over the anticipated 20-year life of the proposed OPC. The proposed OPC would consolidate and replace the existing, undersized, leased Fort Collins MSOC (approximately 10,000 NUSF) and Loveland CBOC (approximately 23,000 NUSF), with a new, appropriately sized, integrated, state-of-the-art facility to support the current and projected future health care needs of Veterans in the area. VA would select a developer (VA developer), who would construct the proposed OPC for VA on a build-to- suit basis, and then lease it to VA for up to 20 years.

The OPC would provide primary care, mental health care, and specialty care outpatient services. The OPC would comply with the Americans with Disabilities Act and meet all requirements set forth in EO 13834: Efficient Federal Operations. The facility would be designed and built to VA design criteria and in accordance with local building and zoning codes.

The OPC would be used Monday through Friday except on federal holidays, and would operate from 7:00 am to 5:00 pm. The OPC would be designed to provide space for approximately 1,000 vehicle stops (staff, patients, volunteers, and other guests) on an average, daily basis. Staff and patients would be primarily drawn from the existing Fort Collins MSOC and Loveland CBOC, although some additional VA staff would likely be required for the expanded services. The OPC would be available to Veterans and service members from all branches of the U.S. Armed Forces who meet the criteria for treatment.

2.3 Alternatives Analysis

The CEQ and VA regulations for implementing NEPA require reasonable alternatives to be explored and objectively evaluated. Alternatives that are eliminated from detailed study must be identified along with a brief discussion of the reasons for eliminating them. For purposes of analysis, an alternative was considered “reasonable” only if it would enable VA to accomplish the primary mission of providing a suitable health care facility that meets the purpose of and need for

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the Proposed Action. “Unreasonable” alternatives would not enable VA to meet the purpose of and need for the Proposed Action.

2.3.1 Alternatives Development

VA undertook a sequential planning and screening process, seeking viable alternatives for the Proposed Action. The results of the process are summarized below:

. After identifying the inadequacies of the existing Fort Collins MSOC and Loveland CBOC to meet the current and increasing demand for health care services by area Veterans, VA examined these facilities for their potential to support the Proposed Action. The existing leased facilities cannot be expanded beyond their current sizes. As such, VA determined that the existing facilities could not be renovated or modified to meet the purpose of and need for the Proposed Action. In addition, continued operation of separate facilities would not enable VA to provide centralized, consolidated outpatient health care services.

. VA then advertised (via a pre-solicitation) for developable land (for new construction) or existing buildings within a delineated area of northern Colorado (Larimer County) to accommodate a 75,645 NUSF one to two-story OPC and 550 on-site parking spaces.

. VA received several responses (expressions of interest) to this advertisement. VA evaluated each of these sites based on surrounding land uses; location of nearest emergency response services; aesthetic quality; current zoning; accessibility to highways, public transportation, shopping, restaurants, and other features; utility availability; overall site condition; site shape and size; topography; floodplains; and visible environmental issues/features. Based on this analysis, VA determined that there appeared to be sufficient potentially suitable locations for the proposed OPC within the delineated area.

. VA then advertised through a Solicitation for Offers for the development and lease of a new 75,645 NUSF, one or two-story clinical building with 550 parking spaces within the delineated area. In response to the solicitation, VA received offers that were within the competitive range for four sites (Sites 1-4). These sites are the Action Alternative sites and are described in Section 2.3.2.

2.3.2 Evaluated Alternatives

Based on the described solicitation process and analysis, VA identified four reasonable sites to establish the proposed OPC (the Action Alternative sites). This EA examines in depth five alternatives, the implementation of the Proposed Action at one of the four Action Alternative sites and the No Action Alternative. The four Action Alternatives are:

Site 1 – 4875 Byrd Drive (Loveland): Site 1 consists of approximately 15 acres of unimproved, agricultural land. Site 1 has been agricultural land since at least the 1940s. The one-story OPC building and associated parking areas would encompass the majority of the site, with the building in the western portion of the site and the parking in the eastern portion of the site. Access would be provided by an access road through an easement from Byrd Drive. Site 1 is depicted on Figures 3 and 4.

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Site 2 – Southwest Corner of East County Road 32 (State Route 392) and Southwest Frontage Road (Fort Collins): Site 2 consists of one approximately 24-acre parcel of unimproved land. The eastern-central portion of the parcel contains wetlands that appear to be associated with off-site Fossil Creek Reservoir. The OPC development would be located on the western portion of the parcel (approximately 15 acres), west of the wetlands. Site 2 has been undeveloped with areas of disturbed land and some agricultural use since at least the 1940s. The one-story OPC building and associated parking areas would encompass the majority of the western portion of the site. Primary and secondary access would be from East County Road 32 (State Route 392/Carpenter Road). Site 2 is depicted on Figures 3 and 5.

Site 3 – Northwest Corner of Ronald Reagan Boulevard and Trade Street (Johnstown): Site 3 consists of approximately 10.4 acres of undeveloped, mostly grassy land. Site 3 was agricultural land from at least the 1940s until 2004, with Farmers Ditch crossing the central portion of the site. In 2005, Farmers Ditch (an irrigation ditch) was rerouted below grade along the northern site boundary, infrastructure was added, and the site area was graded in anticipation of development. Site 3 has been vacant grassy land since 2005. The two-story OPC building and associated parking areas would encompass the majority of the site. Primary access would be from Union Street from the north and Ronald Reagan Boulevard from the south. Secondary access would from Trade Street from the east. Site 3 is depicted on Figures 6 and 7.

Site 4 – Centerra Parkway (Loveland): Site 4 consists of approximately 15 acres of unimproved, agricultural land. Site 4 has been agricultural land since at least the 1940s. The OPC building and associated parking areas would encompass the majority of the site. Access would be provided from a proposed road and a proposed drive from Centerra Parkway. Site 4 is depicted on Figures 6 and 8.

No detailed design plans for the proposed OPC are currently available as this project would be executed as a “Build to Suit Lease.” The VA developer (lessor) would be responsible to design and construct the facility, in compliance with VA design requirements and applicable federal, state and local regulations. The OPC would be a one-story or two-story, approximately 75,645 NUSF, slab-on-grade structure with surrounding paved, surface-level parking lots (total of approximately 550 parking spaces). The majority of the selected site would be developed or altered to accommodate the proposed OPC development. No substantial cutting or filling is anticipated, other than for general site leveling and stormwater detention. The VA design requirements specify that the OPC development must meet a minimum rating of two Green Globes for new construction and sustainable interiors and the building is required to earn an Energy Star label. These VA contract design requirements ensure that the OPC would be sustainably developed. The facility would be leased and operated by VA.

VA anticipates construction of the proposed OPC would begin in 2020 and that the OPC would open in 2022. The new OPC would provide primary care, mental health, and specialty care outpatient services to the area's Veterans. This function is currently provided by two existing VA leased facilities, the Fort Collins MSOC and the Loveland CBOC. VA would no longer lease or operate these facilities once the proposed OPC is open and the existing leases expire.

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No Action Alternative

Under the No Action Alternative, the Proposed Action would not be implemented. VA would continue to provide primary care, mental health, and specialty health care outpatient services at the Fort Collins MSOC and Loveland CBOC. The Action Alternative sites likely would remain vacant for the near future and ultimately be developed by others for other commercial use, in accordance with local zoning. This alternative would limit VA’s ability to provide necessary health care services to U.S. Veterans in the region, and would not meet the purpose of or need for the Proposed Action. However, the No Action Alternative was retained to provide a comparative baseline analysis as required under CEQ regulations.

2.3.3 Alternatives Eliminated from Further Consideration

As described in Section 2.3.1, VA eliminated alternative sites through the screening process. Each of the initially considered sites, with the exception of the four Action Alternative sites, failed to meet the required screening criteria, or were not within the competitive range.

Modification or renovation of the two existing VA health care facilities (Fort Collins and Loveland clinics) in the northern Colorado area is not a viable option as these leased facilities cannot be expanded beyond their current sizes.

VA considered building a new VA-owned facility in the northern Colorado area; however, a VA- owned facility would limit VA’s ability to relocate services in the future and adapt to changes in Veterans health care needs and demographics. A VA-owned facility would also require land acquisition and construction, increasing the cost and lengthening the implementation timeline.

VA considered the renovation of another VA-owned facility; however, no other available VA- owned facilities, suitable for renovation, are located in the northern Colorado area.

VA considered contracting out all primary care, mental health, and specialty care outpatient services to the private health care providers in the community. However, this alternative is not cost-effective and would not guarantee clear access and consistent standard and continuity of care. There also may not be sufficient, qualified, private-sector providers in the northern Colorado area to accommodate the Veteran workload.

VA considered the acquisition of an existing facility in the northern Colorado area through purchase; however, market research and interviews with local VA planners indicated that a suitable facility for possible acquisition and subsequent renovation that would meet all project requirements does not exist in the delineated area of the proposed OPC.

VA also considered a collaboration with the Department of Defense (DoD) for a Joint Lease Project; however, according to local VA planners and VA’s Office of Interagency Health Affairs – Office of VA – DoD Coordination, there are currently no viable facility sharing opportunities in the vicinity of the area.

As such, these other alternatives were eliminated from further consideration.

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SITE 2

KNOXVILLE AVENUE

SITE 1

PREPARED FOR FIGURE 3 U.S. DEPARTMENT OF VETERANS AFFAIRS SITE 1 AND SITE 2 WASHINGTON, DC TOPOGRAPHIC MAP

ENVIRONMENTAL ASSESSMENT TTL PROJECT NO. PROPOSED OPC LARIMER COUNTY, COLORADO 1801701

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FORT COLLINS LOVELAND MUNICIPAL AIRPORT

SITE 1

PREPARED FOR FIGURE 4 U.S. DEPARTMENT OF VETERANS AFFAIRS SITE 1 WASHINGTON, DC AERIAL PHOTOGRAPH

ENVIRONMENTAL ASSESSMENT TTL PROJECT NO. PROPOSED OPC LARIMER COUNTY, COLORADO 1801701

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SITE 2

PREPARED FOR FIGURE 5 U.S. DEPARTMENT OF VETERANS AFFAIRS SITE 2 WASHINGTON, DC AERIAL PHOTOGRAPH

ENVIRONMENTAL ASSESSMENT TTL PROJECT NO. PROPOSED OPC LARIMER COUNTY, COLORADO 1801701

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SITE 4

SITE 3

PREPARED FOR FIGURE 6 U.S. DEPARTMENT OF VETERANS AFFAIRS SITE 3 AND SITE 4 WASHINGTON, DC TOPOGRAPHIC MAP

ENVIRONMENTAL ASSESSMENT TTL PROJECT NO. PROPOSED OPC LARIMER COUNTY, COLORADO 1801701

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SITE 3

PREPARED FOR FIGURE 7 U.S. DEPARTMENT OF VETERANS AFFAIRS SITE 3 WASHINGTON, DC AERIAL PHOTOGRAPH

ENVIRONMENTAL ASSESSMENT TTL PROJECT NO. PROPOSED OPC LARIMER COUNTY, COLORADO 1801701

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SITE 4

PREPARED FOR FIGURE 8 U.S. DEPARTMENT OF VETERANS AFFAIRS SITE 4 WASHINGTON, DC AERIAL PHOTOGRAPH

ENVIRONMENTAL ASSESSMENT TTL PROJECT NO. PROPOSED OPC LARIMER COUNTY, COLORADO 1801701

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SECTION 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

3.1 Introduction

This Section describes the baseline (existing) environmental, cultural, and socioeconomic conditions at the four Action Alternative sites (see Figures 1 through 8) and their general vicinities (that is, the Proposed Action’s Region of Influence (ROI)), with emphasis on those resources potentially impacted by the Proposed Action. Appendix C provides photographs, with captions, of the four Action Alternative sites and their vicinities. Under each resource area (Sections 3.2 through 3.16), the potential direct and indirect effects of implementing the Proposed Action at each of the four Action Alternative sites and the No Action Alternative are identified. Potential cumulative impacts are discussed in Section 3.17.

In this EA, impacts are identified as either significant, less than significant (that is, impacts that would not be of the context or intensity to be considered significant under the CEQ regulations), or no/negligible impact. As used in this EA, the terms “effects” and “impacts” are synonymous. Where appropriate and clearly discernible, each impact is identified as either adverse or beneficial.

The CEQ regulations specify that in determining the significance of effects, consideration must be given to both “context” and “intensity” (40 CFR 1508.27):

Context refers to the significance of an effect to society as a whole (human and national), to an affected region, to affected interests, or to just the locality. Significance varies with the setting of the Proposed Action.

Intensity refers to the magnitude or severity of the effect, and whether it is beneficial or adverse.

In this EA, the significance of potential direct, indirect, and cumulative effects has been determined through a systematic evaluation of each considered alternative in terms of its effects on each individual environmental resource component.

Resource areas considered in this EA are as follows:

. Aesthetics . Socioeconomics . Air Quality . Community Services . Cultural Resources . Solid Waste and Hazardous Materials . Geology, Topography, and Soils . Transportation and Parking . Hydrology and Water Quality . Utilities . Wildlife and Habitat . Environmental Justice . Noise . Cumulative Impacts . Land Use . Potential for Generating Substantial . Floodplains, Wetlands, and Coastal Zone Controversy Management

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3.2 Aesthetics

Site 1

Site 1 is located in a mixed-use (commercial, industrial, and agricultural) area approximately 4.8 miles northeast of the center of the City of Loveland. Site 1 is located within the limits of the City of Loveland. Site 1 includes approximately 15 acres of unimproved, agricultural land and is located within the southern portion of a master planned, approximately 142-acre retail and office/business park (Brands West). Interstate 25 is located approximately 1,500 feet east of the site. Site 1 is depicted on Figure 4.

Adjacent to the north and east of the Site 1 is unimproved agricultural land. Adjacent to the south of Site 1 is a Western Area Power Administration/U.S. Department of Energy facility. Adjacent to the west of Site 1 is unimproved land associated with the Northern Colorado Regional Airport (Fort Collins-Loveland Municipal Airport).

Site 2

Site 2 is located in a mixed-use (commercial, recreational, and residential) area approximately 6.7 miles northeast of the center of the City of Loveland and approximately 8.5 miles southeast of the center of the City of Fort Collins. Site 2 is located within the limits of the City of Fort Collins. Site 2 consists of approximately 24 acres of unimproved land located at the southwest corner of the intersection of East County Road 32 (State Route 392/Carpenter Road) and Southwest Frontage Road (a service drive along Interstate 25). The eastern-central portion of the site contains wetlands that appear to be associated with off-site Fossil Creek Reservoir. Site 2 is depicted in Figure 5.

Adjacent to the north of the Site 2 (across East County Road 32/State Route 392/Carpenter Road) are unimproved grassy land and wetlands associated with the 1,398-acre Fossil Creek Reservoir Natural Area. Adjacent to the east of Site 2 is Southwest Frontage Road, beyond which is a commuter parking lot, a grassy landscaped area with a few trees and Interstate 25. Adjacent to the south of Site 2 are commercial properties (RTN Roofing Systems, Ander’s Auto Glass, and Lucky Star Equine Management), grassy unimproved land, and a horse training track. Adjacent to the west of Site 2 is grassy unimproved land, beyond which is Hazel Dell Mushrooms farm. A residential neighborhood is located approximately 600 feet southwest of Site 2.

Site 3

Site 3 is located in a mixed-use (commercial, light industrial, and residential) area approximately 5.5 miles east-northeast of the center of the City of Loveland. Site 3 is located within the limits of the Town of Johnstown. Site 3 includes approximately 10.4 acres of unimproved, mostly grassy land and is located within a 600-acre master planned mixed-use (office, retail, light industrial and residential) development area (2534 Development). Interstate 25 is located approximately one mile west of the site. Site 3 is depicted on Figure 7.

Adjacent to the north of the Site 3 (across Union Street) is the Northern Colorado Rehabilitation Hospital and grassy unimproved land. Adjacent to the east of Site 3 (across Trade Street) is grassy unimproved land. Adjacent to the south of Site 3 (across Ronald Reagan Boulevard) are High Country Beverage (southeast), grassy unimproved land (south), and a residential

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subdivision (southwest). Adjacent to the west of Site 3 are Arete Surgical Center and medical office buildings.

Site 4

Site 4 is located in a mixed-use (commercial and agricultural) area approximately 5.1 miles northeast of the center of the City of Loveland. Site 4 is located within the limits of the City of Loveland. Site 4 includes approximately 15 acres of unimproved, agricultural land within the northern portion of the 3,000-acre Centerra master planned community. Interstate 25 is located approximately 1,600 feet west of the site. Site 4 is depicted on Figure 8.

Adjacent to the north, south, and west of the Site 4 is agricultural land. Farther north is a light industrial/commercial business park. Adjacent to the east of Site 4 (across Centerra Parkway) is unimproved agricultural land.

3.2.1 Effects of the Action Alternatives

VA’s closure of the existing Fort Collins MSOC and Loveland CBOC, leased facilities owned by others, would have no aesthetics impacts. These facilities would likely be leased by the owners for other commercial use.

Site 1

The Proposed Action at Site 1 would result in negligible aesthetic impacts. Site 1 is located in a master planned retail and office/business park in a developing area of commercial/light industrial properties. The new OPC would be an attractive one-story medical office building that would be designed and constructed in a way that is visually consistent with the development of the surrounding area, built in accordance with the City of Loveland’s development standards. Existing on-site grassy land would be mostly eliminated and views from the surrounding areas would be altered by the OPC development. However, no sensitive receptors are located in the Site 1 area and any visual effects would be minimized through an attractive OPC design and landscaping.

Site 2

The Proposed Action at Site 2 would result in less-than-significant aesthetic impacts. Site 2 is located in a mixed-use area with commercial and residential properties, and mostly unimproved natural areas. The new OPC would be an attractive one-story medical office building that would be designed and constructed in a way that is visually consistent with the mixed-use development of the surrounding area, built in accordance with the City of Fort Collins’ development standards. Existing on-site green space in the western portion of the site would be mostly eliminated and views from the surrounding areas would be altered by the OPC development. The wetland areas located in the central and eastern portions of the site would be undisturbed by the OPC development. The nearest sensitive viewshed receptors (residential neighborhood southwest of the site) are located approximately 600 feet from the site. Visual effects would be minimized through an attractive OPC design and landscaping.

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Site 3 The Proposed Action at Site 3 would result in less-than-significant aesthetic impacts. Site 3 is located in a rapidly developing, master planned, mixed use (office, retail, light industrial, and residential) area and is surrounded by medical offices, a hospital, light industrial properties, and new residences (to the southwest beyond Ronald Reagan Boulevard). The new OPC would be an attractive two-story medical office building that would be designed and constructed in a way that is visually consistent with the mixed-use development of the surrounding area, built in accordance with the Town of Johnstown’s development standards. Existing on-site green space would be mostly eliminated and views from the surrounding areas would be altered by the OPC development. Visual effects on sensitive receptors located to the southwest of Site 3 (residences) would be minimized through an attractive OPC design and landscaping.

Site 4 The Proposed Action at Site 4 would result in negligible aesthetic impacts. Site 4 is located in a large master planned mixed use development area, although the immediate site area is currently mostly unimproved agricultural land with a commercial/light industrial park located to the north. The new OPC would be an attractive one-story medical office building that would be designed and constructed in a way that is visually consistent with the planned mixed-use development of the surrounding area, built in accordance with the City of Loveland’s development standards. Existing on-site agricultural land and green space would be mostly eliminated and views from the surrounding areas would be altered by the OPC development. However, no sensitive receptors are located in the Site 4 area and any visual effects would be minimized through an attractive OPC design and landscaping.

3.2.2 Effects of the No Action Alternative

Under the No Action Alternative, no aesthetics impacts by VA would result. The Action Alternative sites would likely be developed for commercial use by others, consistent with local zoning. Aesthetics impacts similar to those associated with the Proposed Action could occur, depending on the use of the sites.

3.3 Air Quality

3.3.1 Ambient Air Quality

The ambient air quality in an area can be characterized in terms of whether or not it complies with the primary and secondary National Ambient Air Quality Standards (NAAQS). The Clean Air Act(CAA) requires the U.S. Environmental Protection Agency (USEPA) to set NAAQS for pollutants considered harmful to public health and the environment. NAAQS are provided for the following principal pollutants, called “criteria pollutants” (as listed under Section 108 of the CAA):

. Carbon monoxide . Lead . Nitrogen oxides . Ozone . Particulate matter, divided into two size classes: Aerodynamic size less than or equal to 10 micrometers Aerodynamic size less than or equal to 2.5 micrometers . Sulfur dioxide

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Areas are designated by the USEPA as “attainment”, “non-attainment”, “maintenance”, or “unclassified” with respect to the NAAQS. Regions in compliance with the standards are designated as “attainment” areas. In areas where the applicable NAAQS are not being met, a “non-attainment” status is designated. Areas that have been classified as "non-attainment", but are now in compliance can be re-designated "maintenance" status, if the state completes an air quality planning process for the area. Areas for which no monitoring data is available are designated as “unclassified”, and are by default considered to be in attainment of the NAAQS. According to the USEPA Green Book (June 2019), the area of Larimer County that includes the four Action Alternative sites is designated as a moderate non-attainment area for ozone (8-hour 2008 standard) and an attainment area for the remaining NAAQS.

3.3.2 Sensitive Receptors

Sensitive air quality receptors in the vicinity of Action Alternative sites include a residential area located approximately 600 feet southwest of Site 2, residences located southwest of Site 3 beyond Ronald Reagan Boulevard, medical offices located westerly adjoining Site 3, and the Northern Colorado Rehabilitation Hospital located northerly adjoining Site 3 beyond Union Street. No sensitive air quality receptors were identified in the vicinity of Site 1 and Site 4.

3.3.3 Effects of the Action Alternatives

Air emissions generated from the Proposed Action would have less-than-significant direct and indirect, short-term and long-term adverse impacts to the existing air quality environment around the selected Action Alternative site. Impacts would include short-term and long-term increased air emission levels as a result of construction activities and operation of the proposed OPC and onsite activities.

Construction activities would be performed in accordance with federal and state air quality requirements. Construction-related emissions are generally short-term, but may still have adverse impacts on air quality, primarily due to the production of dust. Dust can result from a variety of activities, including excavation, grading, and vehicle travel on paved and unpaved surfaces. Dust from construction can lead to adverse health effects and nuisance concerns, such as reduced visibility on nearby roadways. The amount of dust is dependent on the intensity of the activity, soil type and conditions, wind speed, and dust suppression activities used. Implementing dust control measures (BMPs) greatly reduces dust emissions from construction. Construction-related emissions also include the exhaust from the operation of construction equipment, including diesel particulate matter. The BMP to use newer construction equipment with emissions controls and minimizing the time that the equipment is idling reduces construction equipment exhaust emissions. Implementation of BMPs, discussed in Section 5, would minimize these anticipated less-than-significant adverse, short-term impacts.

Operational (long-term) air quality impacts from the proposed OPC would include emissions from equipment, such as boilers and generators, and vehicle emissions from patients and staff driving to and from the OPC. The Proposed Action would result in daily site visits by approximately 1,000 patients, staff, volunteers, and guests. As such, there would be a localized, less-than-significant, increase in vehicle air emissions at the selected Action Alternative site. However, regional vehicle emissions would be similar to current emissions as most patients and staff that would use the proposed OPC currently travel to the existing Fort Collins MSOC and Loveland CBOC.

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A Title V operating permit is not anticipated to be required for the proposed OPC’s boiler equipment, generators, and other equipment as this equipment is not anticipated to emit more than 100 tons per year of any individual or combination of hazardous air pollutants. However, VA’s selected developer would secure any required air emissions permits from the Colorado Department of Public Health and Environment (CDPHE) Air Pollution Control Division, as appropriate and based on the final design.

The Action Alternative sites are located within a NAAQS ozone moderate non-attainment area; therefore, VA would be subject to the General Conformity Rule of the CAA for the Proposed Action. However, based on air quality modeling for similar projects, short-term construction- related air emissions and long-term operational emissions are anticipated to be well below the de minimis level (100 tons/year) for moderate ozone non-attainment areas. As such, a Conformity Determination is not required.

VA’s closure of the existing leased Fort Collins MSOC and Loveland CBOC would have negligible air quality impacts. These facilities would likely be leased by others for commercial use with similar operational air emissions.

3.3.4 Effects of the No Action Alternative

Under the No Action Alternative, no air quality impacts related to construction or operation of the proposed OPC would occur. Should the Action Alternative sites ultimately be developed for use by others, air quality impacts could result, depending upon the future use.

3.4 Cultural Resources

Site 1

Site 1 has been unimproved and/or agricultural land since at least the 1940s. Site 1 is not listed on the National Register of Historic Places (NRHP). A&B Cultural Consultants, LLC (A&B) completed a Cultural Resources Inventory of Site 1 in April 2019. No historic buildings or structures were identified at the site. Colorado Office of Archaeology and Historic Preservation (OAHP) files list no recorded archaeological sites within Site 1. No historic properties eligible for listing in the NRHP were identified at the site or surrounding properties.

Site 2

Site 2 has been unimproved and somewhat disturbed land with some agricultural use since at least 1940s. The central and eastern portions of the site appear to contain a drainage area/wetlands associated with Fossil Creek Reservoir located to the north of Site 2 beyond East County Road 32 (State Route 392/Carpenter Road). Site 2 is not listed on the NRHP. A Class I Cultural Resources Review was conducted for Site 2 by Logan Simpson in November 2018. No historic buildings or structures were identified at the site and no recorded archaeological sites were listed for Site 2 in OAHP files. No historic properties eligible for listing in the NRHP were identified at Site 2 or surrounding properties.

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Site 3

Site 3 has been unimproved and/or agricultural land since at least the 1940s. Farmers Ditch (a historic irrigation channel) crossed the central portion of Site 3 until 2005, when the site and surrounding area were prepared for commercial development. As part of the pre-development, Farmers Ditch was rerouted; the ditch now flows through underground piping along the northern site boundary. Segments of the original Farmers Ditch were identified as eligible for inclusion on the NRHP. However, based on its modifications, VA has determined that the segment of Farmers Ditch that is located at Site 3 is not eligible for inclusion on the NRHP. No historic properties eligible for listing in the NRHP were identified at Site 3.

Site 4

Site 4 has been unimproved and/or agricultural land since at least the 1940s. Site 4 is not listed on the NRHP. A Cultural Resources Desktop Review was conducted for Site 4 by AK Pioneer Consulting in May 2019. No historic buildings or structures were identified at the site. OAHP files indicate one prehistoric isolated find was previously identified in the southeastern portion of Site 4; however, the find was determined to be ineligible for listing in the NRHP. No historic properties eligible for listing in the NRHP were identified at Site 4 or the surrounding properties.

3.4.1 Effects of the Action Alternatives

Based on the findings of the cultural resources assessments completed for the sites and other available information, the implementation of the Proposed Action at any of the Action Alternative sites would not affect NRHP-listed or eligible historic properties. No such properties have been identified at the Action Alternative sites.

VA initiated National Historic Preservation Act Section 106 consultation with the History Colorado Office of Archaeology and Historic Preservation (Colorado State Historic Preservation Office or SHPO) on June 18, 2019, requesting concurrence with a determination that no historic properties would be affected by the Proposed Action. The Colorado SHPO response to this determination is pending. VA also sent letters on June 13, 2019, to the six federally recognized Native American Tribes identified as having possible ancestral ties to Larimer County, requesting input regarding the Proposed Action. One response received to date, from the Northern Cheyenne Tribe, stated that it appeared the Proposed Action would have no effect.

VA’s closure of the leased Fort Collins MSOC and Loveland CBOC would have no cultural resources impacts.

3.4.2 Effects of the No Action Alternative

Under the No Action Alternative, no cultural resources impacts related to construction by VA would occur. Should the Action Alternative sites be developed for use by others, it is unlikely that significant cultural resources impacts would occur.

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3.5 Geology and Soils

The eastern portion of Larimer County, where the Action Alternative sites are located, is situated in the Colorado Piedmont section of the Great Plains physiographic region. The Colorado Piedmont lies between the High Plains and the Front Range of the Rockies, at elevations distinctly lower than the High Plains surface, and consists of a series of river terraces on which major urban centers of Colorado (Colorado Springs, Denver, and Fort Collins) have developed. These terraces represent former floodplain levels of the South Platte and Arkansas Rivers and their principal Rocky Mountain tributaries and were formed as they cut down through and removed the old High Plains' surface and its underlying fluvial deposits. In many places, terrace surfaces and the surrounding dissected bedrock landscape are covered by small sand dune fields (University of Nebraska-Lincoln 2011).

The Action Alternative sites are underlain by Pierre Shale, a bedrock formation of Cretaceous age. The Pierre Shale consists of shale or mudstone with localized beds of sandstone. Unconsolidated sediments overlie much of the bedrock in the Action Alternative sites areas. The unconsolidated sediments are of Quaternary age and are composed of alluvium, colluvium, and eolian deposits. Depth to bedrock in the Fort Collins/Loveland/Boulder Colorado areas is generally less than 50 feet below ground surface (bgs) (USGS 2000).

Large areas of Colorado are underlain by Mesozoic and/or Paleozoic evaporite deposits. These minerals, including anhydrite, halite, and gypsum, dissolve in the presence of fresh water and create subsurface voids. Settlement and collapse of the ground surface into these subsurface voids can create ground depressions and sinkholes, known collectively as karst landforms. There are no known surface or near-surface evaporite deposits or other karst features located at the Action Alternative sites (Colorado Geologic Survey (CGS) 2012).

There are hundreds of abandoned underground coal mines throughout Colorado that present potential subsidence hazards to structures and surface improvements. These hazards include the potential for sagging ground, sinkhole development, and the collapse of mine shafts that have not been appropriately closed (Colorado Division of Reclamation, Mining and Safety (DRMS) 2019). Based on a review of available maps obtained from the DRMS, no abandoned coal mines were identified in the Action Alternative site areas.

The State of Colorado oversees numerous oil and gas wells. Based on site observations and a review of available maps obtained from the Colorado Oil and Gas Conservation Commission, no active or orphaned oil and gas wells were observed or known to be located on the Action Alternative sites. The Action Alternative sites are not located in areas of known oil and gas fields. However, two active oil and gas wells are located to the east of Site 4 (approximately 1,900 feet east and 1,350 feet southeast, respectively).

More than 700 earthquake tremors of magnitude 2.5 or higher on the Richter scale have been recorded in Colorado since 1867. Most earthquakes are caused by movement of faults; however, earthquakes in Colorado have also been triggered by deep well injection. The largest known earthquake in Colorado occurred on November 7, 1882, and had an estimated magnitude of 6.6. The location of this earthquake was in the northern Front Range, west of Fort Collins. The closest recent earthquake occurred on March 30, 1990, registered 2.9 on the Richter scale, and was reportedly located approximately 4.5 miles northeast of Greeley, Colorado (over 18 miles east of the Action Alternative sites) (USGS 2019). The seismic hazard in Colorado is considered to be

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low to moderate (CGS 2019). No active faults were identified at or near the Action Alternative sites.

Site 1

A review of the Windsor and Loveland, Colorado USGS Topographic Quadrangles (dated 2016) and site reconnaissance conducted in June 2019 indicated the surficial topography of Site 1 slopes slightly to the southwest, with elevations ranging from approximately 5,045 feet above mean sea level (amsl) in the eastern portion of the site to approximately 5,025 feet above amsl in the southwestern portion of the site. The surface water bodies nearest to Site 1 depicted on the topographic maps include an intermittent stream located approximately 4,350 feet east of the site and Boyd Lake located approximately 6,500 feet west of the site. Figure 3 depicts the topography of Site 1 and the surrounding area.

According to the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Web Soil Survey, Site 1 contains two soil types identified as Ulm clay loam, 0 to 3 percent slopes (majority of site) and Wiley silt loam, 3 to 5 percent slopes (southeastern and east-central portions). The Ulm soil series consists of mixed alluvium derived from shale and contains well-drained clay loam and clay. The Wiley soil series consists of uniform eolian deposits and contains well drained silt loam, silty clay loam, clay loam, and loam. Site 1 soils are shown on Figure 9.

Site 2

A review of the Windsor and Loveland, Colorado USGS Topographic Quadrangles (dated 2016) and site reconnaissance conducted in June 2019 indicated the surficial topography of Site 2 slopes towards the central portion of the site, with elevations ranging from approximately 4,890 feet amsl in the eastern and western portions to approximately 4,870 feet amsl in the north-central portion of the site. The nearest surface water body depicted on the topographic map is Swede Lake (part of Fossil Creek Reservoir), located approximately 650 feet north of Site 2. A wetland area and an irrigation ditch are located in the central portion of the site. Figure 3 depicts the topography of Site 2.

According to the USDA NRCS Web Soil Survey, Site 2 contains five soil types identified as Kim loam, 5 to 9 percent slopes (western portion), Longmont clay, 0 to 3 percent slopes (central and eastern portions), Nunn clay loam, 1 to 3 percent slopes (southwestern portion), Nunn clay loam, wet, 1 to 3 percent slopes (northwestern portion), and Wiley silt loam, 3 to 5 percent slopes (eastern portion). The Kim soil series consists of mixed alluvium and contains well drained loam, clay loam, sandy clay loam. The Longmont soil series consists of clayey alluvium derived from shale and contains poorly drained clay. The Nunn soil series consists of alluvium and/or eolian deposits and contains well drained clay loam and somewhat poorly drained clay loam, clay, and gravelly sandy loam. The Wiley soil series consists of uniform eolian deposits and contains well drained silt loam, silty clay loam, clay loam, and loam. Site 2 soils are shown on Figure 9.

Site 3

A review of the Windsor, Colorado USGS Topographic Quadrangle (dated 2016) and site reconnaissance conducted in June 2019 indicated the surficial topography of Site 3 slopes slightly to the southwest, with elevations ranging from approximately 4,930 feet amsl in the northern and eastern portions to approximately 4,920 feet amsl in the southwestern portion of the site. The

DRAFT ENVIRONMENTAL ASSESSMENT 24 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS AFFECTED ENVIRONMENT/ENVIRONMENTAL CONSEQUENCES nearest surface water bodies depicted on the topographic map include: Farmers Ditch, an irrigation ditch that formerly crossed the central portion of the site that has been rerouted; Loveland and Greeley Canal, located approximately 1,000 feet north of the site; and the Big Thompson River, located approximately 3,150 feet south of the site. Figure 6 depicts the topography of Site 3.

According to the USDA NRCS Web Soil Survey, Site 3 contains three soil types identified as Nunn clay loam, 1 to 3 percent slopes (northwestern and southeastern portions), Nunn clay loam, wet, 1 to 3 percent slopes (majority of Site 3), and Stoneham loam, 1 to 3 percent slopes (south-central portion). The Nunn soil series consists of alluvium and/or eolian deposits and contains well drained clay loam and somewhat poorly drained clay loam, clay, loam, and gravelly sandy loam. The Stoneham soil series consists of mixed alluvium and/or eolian deposits and contains well drained loam, clay loam, and sandy clay loam. Site 3 soils are shown on Figure 9.

Site 4

A review of the Windsor, Colorado USGS Topographic Quadrangle (dated 2016) indicated that surficial topography of Site 4 slopes slightly to the south with an elevation around approximately 5,010 feet amsl. A stormwater drainage culvert appears to run north-south beneath the west- central portion of the site, surfaces near the southern site boundary, and continues to flow south across the southerly adjacent property. The nearest surface water body depicted on the topographic map is an intermittent stream located approximately 1,070 feet southeast of the site. Figure 6 depicts the topography of Site 4.

According to the USDA NRCS Web Soil Survey, Site 4 contains two soil types identified as Stoneham loam, 5 to 9 percent slopes (central portion), and Weld silt loam, 0 to 3 percent slopes (eastern and western portions). The Stoneham soil series consists of mixed alluvium and/or eolian deposits and contains well drained loam, clay loam, and sandy clay loam. The Weld soil series consists of calcareous loess and contains well drained silt loam and silty clay. Site 4 soils are shown on Figure 9.

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SITE 1 SITE 2

76 55 113 119 63 74 119

113 – Ulm clay loam, 0 to 3 percent slopes 55 – Kim loam, 5 to 9 percent slopes 119 – Wiley silt loam, 3 to 5 percent slopes 63 – Longmont clay, 0 to 3 percent slopes 74 – Nunn clay loam, 1 to 3 percent slopes 76 – Nunn clay loam, wet, 1 to 3 percent slopes 119 – Wiley silt loam, 3 to 5 percent slopes

74 76 115 103 115

74 74 101 SITE 3 SITE 4 74 – Nunn clay loam, 1 to 3 percent slopes 103 – Stoneham loam, 5 to 9 percent slopes 76 – Nunn clay loam, wet, 1 to 3 percent slopes 115 – Weld silt loam, 0 to 3 percent slopes 101 – Stoneham loam, 1 to 3 percent slopes PREPARED FOR FIGURE 9 U.S. DEPARTMENT OF VETERANS SITE SOILS MAPS AFFAIRS

ENVIRONMENTAL ASSESSMENT WASHINGTON, DC PROPOSED OPC LARIMER COUNTY, COLORADO TTL PROJECT NO. 1801701

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3.5.1 Prime and Unique Agricultural Land Soils

Prime and Unique Farmlands are regulated in accordance with the Farmland Protection Policy Act (FPPA) to ensure preservation of agricultural lands that are of statewide or local importance. Soils designated as prime farmland are capable of producing high yields of various crops when managed using modern farming methods. Prime farmland is land that has the best combination of physical and chemical characteristics for producing food, feed, fiber, forage, oilseed, and other agricultural crops with minimum inputs of fuel, fertilizer, pesticides, and labor, and without intolerable soil erosion. Unique farmlands are also capable of sustaining high crop yields and have special combinations of favorable soil and climate characteristics that support specific high- value foods or crops.

According to the USDA NRCS Web Soil Survey, all of the soils at each of the four Action Alternative sites are classified as prime farmland or farmland of local importance.

Site 2 is located in an area identified by the U.S. Census Bureau as an “urbanized area” and is exempt from the FPPA. Sites 1, 3, and 4 are not exempt from the FPPA, regardless of their current use or zoning for commercial development.

3.5.2 Effects of the Action Alternatives

No major changes to topography would occur at the selected Action Alternative site due to the Proposed Action. The OPC would be designed in concert with the selected site’s topography. All of the Action Alternative sites are generally level. Although some grading would be required, it is anticipated that the OPC building and parking areas would be constructed near current grades.

Less-than-significant impacts to geology are anticipated. No active active or inactive faults are known to extend through the subsurface geology at the Action Alternative sites. As such, no impacts associated with seismic hazards are identified. The Action Alternative sites are not located in areas with known oil and gas, coal, or other mineral resources. No significant impacts to mineral resources are anticipated, as the Proposed Action would not involve the commercial extraction of mineral resources, nor affect mineral resources considered important on a local, state, national, or global basis. The Proposed Action would impact prime agricultural land or farmland of local importance; however, all four sites have been planned and zoned for commercial or light industrial development by their respective municipalities.

Farmland soil impacts would be less than significant. If Sites 1, 3, or 4 are selected for the OPC, VA would complete form AD-1006 (Farmland Conversion Impact Rating) in conjunction with USDA NRCS for the selected site. Form AD-1006 is not required for Site 2, which is located within a designated urban area.

During construction, less-than-significant, direct and indirect, short-term soil erosion and sedimentation impacts would be possible as the proposed building, parking areas, entrance road, and other project components are constructed. Construction would remove the vegetative cover, disturb the soil surface, and compact the soil. The soil would then be susceptible to erosion by wind and surface runoff. Exposure of the soils during construction has the potential to result in increased sedimentation to stormwater management systems and offsite discharges of sediment- laden runoff. However, such potential adverse erosion and sedimentation effects would be prevented through utilization of appropriate BMPs (Section 5) and adherence to the terms of an approved General Permit to Discharge under the Colorado-administered National Pollutant

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Discharge Elimination System (NPDES) program for construction activities including the development and implementation of a site-specific Stormwater Pollution Prevention Plan (SWPPP).

Once construction is complete, no long-term erosion and sedimentation impacts would be anticipated. No long-term soil erosion impacts would occur as a result of increased impervious surfaces onsite; these effects would be mitigated by including appropriately designed stormwater management systems as part of final site design.

VA’s closure of the leased Fort Collins MSOC and Loveland CBOC would have no geology and soil soils impacts.

3.5.3 Effects of the No Action Alternative

Under the No Action Alternative, no construction by VA’s selected developer would occur. No impacts to soils, topography, or geology would occur at the Action Alternative sites as a result of VA’s actions. However, the Action Alternative sites would likely be developed by others for commercial use and impacts similar to those as identified above could occur.

3.6 Hydrology and Water Quality

3.6.1 Surface Waters

The South Platte River Basin is located in northeastern Colorado and covers approximately 27,660 square miles within the state, including the Action Alternative sites. The South Platte River Basin is subdivided into sixteen districts. Site 2 is located in the Cache La Poudre River water district and Sites 1, 3, and 4 are located in the Big Thompson River water district (CSU 2019). The Cache la Poudre River watershed drains approximately 1,056 square miles above the canyon mouth west of Fort Collins. In an average year, the Cache la Poudre River watershed produces approximately 274,000 acre feet of water. More than 80 percent of the production (223,000 acre feet) occurs during the peak snowmelt months of April through July. The Big Thompson River watershed drains about 305 square miles above the canyon mouth west of Loveland. In an average year, the Big Thompson River watershed produces about 124,000 acre-feet of water. Nearly 75% of the production (93,000 acre-feet) occurs during the peak snowmelt months of April through July (Northern Colorado Water Conservancy District 2019).

The municipal drinking water available to the site areas comes from nearby surface waters. Loveland’s raw water supply comes from the Big Thompson River and Green Ridge Glad Reservoir (Loveland Water Quality Report 2018). Fort Collins’ drinking water supply comes from the upper Cache la Poudre River and Horsetooth Reservoir (Fort Collins Water Quality Report 2018). Johnstown’s drinking water supply comes from the Johnstown Reservoir, the Little Thompson Water District, and the Big Thompson River (Johnstown Water Quality Report 2017).

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Site 1

Site 1 is located in the Big Thompson River watershed. Big Thompson River is located approximately 2.8 miles south of the site. No surface waters were identified or observed on or near Site 1 (see Figures 3 and 4). The nearest surface water is an intermittent stream located approximately 4,350 feet east of the site. Stormwater at Site 1 generally infiltrates into onsite soils.

Site 2

Site 2 is located in the Cache La Poudre River watershed. The Cache La Poudre River is located approximately 1.7 miles northeast of the site. The central and southeastern portions of the site contain a wetlands area that appears to be hydraulically associated with Swede Lake (part of Fossil Creek Reservoir), located approximately 650 feet north of the site beyond East County Road 32. An irrigation ditch runs north-south approximately 100 to 250 feet west of the main wetland area. Refer to Section 3.10 for further information pertaining to wetlands. No other surface waters were identified on the site or immediately adjacent areas. Stormwater at Site 2 generally infiltrates into onsite soils or flows towards the irrigation ditch located in the central portion of the site, stormwater drainage ditches along the northern site boundary (along East County Road 32), and along the eastern site boundary, and into the central wetland portion of the site (see Figure 5).

Site 3

Site 3 is located in the Big Thompson River watershed. The Loveland Greeley Canal is located approximately 1,000 feet north of the site and Big Thompson River is located approximately 3,140 feet south of the site. Farmers Ditch formerly crossed the central portion of the site; however, Farmers Ditch was rerouted and partially enclosed in below grade pipe, when the area was prepared for development in the mid-2000s. A stormwater retention pond located approximately 400 feet south of the site was also created during this time. Farmers Ditch now flows through below grade piping along the northern site boundary. A segment of the ditch is above grade east of the site, beyond Trade Street. No other surface waters were identified at or near Site 3 (see Figures 6 and 7). Stormwater at Site 3 generally infiltrates into onsite soils or flows into stormwater catch basins located along Ronald Reagan Boulevard (southerly adjoining), Trade Street (easterly adjoining), and Union Street (northerly adjoining). Stormwater collected in the catch basin flows to the retention pond south of the site.

Site 4

Site 4 is located in the Big Thompson River watershed. The Big Thompson River is located approximately 1.9 miles south of the site. No surface waters were identified or observed on or near Site 4. A piped stormwater drain crosses the southwestern portion of Site 4 and discharges to an outfall located near the southern site boundary. From the outfall, the drain continues to flow to the south across the adjacent property and discharges to a regional stormwater detention pond located approximately 2,000 feet south of the site (see Figure 8). Stormwater at Site 4 generally infiltrates into onsite soils or flows over ground towards the open stormwater drainage ditch located near the southern site boundary.

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3.6.2 Groundwater

The South Platte River Basin is comprised of two regions, mountains and plains. The western part of the basin contains high, rugged mountains, while the eastern plains area (Action Alternative sites area) is an area of low relief and low precipitation. Most of the rocks in the basin are water bearing (CGS 1974). The South Platte Basin supports a wide range of water needs including municipal, industrial, agricultural, ecological and recreational attributes.

Depth to the shallow water table in the Action Alternative sites area is generally less than 50 feet bgs. The shallow aquifers may be thin, discontinuous, or transient, and the water table may be in the bedrock during much of the year. If shallow aquifers are present, the water table is generally near the top of the bedrock (USGS 2000).

According to the Colorado Department of Natural Resources (CDNR) Division of Water Resources Well Permit Research Viewer, one water well is located approximately 1,400 feet south of Site 2. The well was installed in 1959 and registered October 1960 for drinking water use by the Colorado Parks and Recreation Department for the Fossil Creek Roadside Park. The well was drilled to a depth of 1,160 feet and depth to groundwater was reported to be 20 feet bgs. Geology in the vicinity of the well was reported to be 30 feet of yellow clay, overlying 170 feet of blue shale, 300 feet of gray shale, 600 feet of gray and brown shale layers, 30 feet of limestone, and 60 feet of gray sandstone to the depth of well termination at 1,160 feet. One water well is located approximately 1,530 feet southwest of Site 3. The well was installed in 1954 for stock use by an individual. The well was drilled to a depth of 142 feet and depth to groundwater was reported to be 40 feet bgs. Geology in the vicinity of the well was reported to be 5 feet of soil overlying 6 feet of clay, 16 feet of yellow sandy shale, 1 foot of hard rock, 35 feet of hard brown sand rock, 2 feet of hard rock, 7 feet of dark brown sand rock, 2 feet of hard rock, 7 feet of hard brown sand rock, 59 feet of gray sand rock, and 2 feet of gray sandy shale (CDNR 2019). No water wells were identified in the general vicinity of Sites1 and 4 and no water wells were identified on any of the Action Alternative sites. Groundwater is generally not used as a potable water source in the Action Alternative sites area. The potable water services are provided to the site vicinities by their respective municipalities or water districts, which source their water from nearby surface waters.

3.6.3 Effects of the Action Alternatives

The Action Alternatives would not result in significant impacts to surface waters, provided the BMPs described in Section 5 are implemented. These BMPs would control construction-related impacts of soil erosion and sedimentation, and would provide proper stormwater management following the OPC development. Anticipated stormwater management for each site is described below.

Site 1

Stormwater from the proposed OPC development at Site 1 would be managed in an on-site detention pond that would be constructed on the southwestern portion of the site. The on-site detention pond would connect to the existing regional stormwater management system for the Brands West development which would convey overflow stormwater from the site through open channel ditches to a regional detention pond located approximately 2,300 feet southwest of the site.

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Site 2

The OPC would be constructed outside of (west) of the wetland areas. It is anticipated that stormwater from the proposed OPC development at Site 2 would be managed through on-site detention ponds constructed in the northwestern portion of the site and west of the main wetland area. Detention pond outlets would discharge to the wetland. The existing irrigation ditch would remain, unaltered.

Site 3

Stormwater from the proposed OPC development at Site 3 would be conveyed to the stormwater drain system associated with the master planned 2534 Development area. Drainage pipes along the perimeter of the site convey stormwater to the retention pond located approximately 400 feet south of the site.

Site 4

At Site 4, the existing stormwater drain would be modified (extended) to discharge farther south (beyond a proposed road). Stormwater inlets associated with the proposed OPC would primarily discharge to this existing stormwater drain, which flows to the south to a regional stormwater detention pond. Some stormwater from the OPC would also flow to the existing stormwater sewer located within Centerra Parkway, which also discharges to the regional stormwater detention pond located approximately 2,000 feet south of the site. Stormwater within the on-site drain and stormwater sewer within the road are managed as part of the Centerra master planned development.

With each of the Action Alternatives, the OPC development design would meet the Energy Independence and Security Act (EISA) Section 438 requirements with respect to stormwater runoff quantity and characteristics and would maintain the predevelopment hydrology to the maximum extent technically feasible.

The proposed OPC would be a slab-on-grade building and serviced with a municipal water supply. Therefore, it is not anticipated that groundwater would be encountered or impacted by the Proposed Action. If limited areas of deeper excavation are required (such as for utility installation) and shallow groundwater is encountered during construction (very unlikely), appropriate groundwater engineering controls would be utilized to ensure no adverse effects to groundwater.

3.6.4 Effects of the No Action Alternative

Under the No Action Alternative, no construction by VA’s selected developer would occur. No impacts to water resources at the sites would occur as a result of the VA’s actions. However, should the sites be developed for commercial use by others, impacts similar to those as identified above could occur.

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3.7 Wildlife and Habitat

3.7.1 Vegetation and Wildlife

Site 1

Site 1 consists of approximately 15 acres of unimproved, previously cultivated, grassy agricultural land. Site 1 has been agricultural land since at least the 1940s. No native vegetation is present on the site. The vegetative communities on Site 1 could support limited wildlife species associated with suburban areas in northern Colorado.

Site 2

Site 2 consists of approximately 24 acres of unimproved land with a few trees along the western site boundary. The eastern-central portion of the parcel contains wetlands that appear to be associated with off-site Fossil Creek Reservoir and a small irrigation ditch. Site 2 has been undeveloped with areas of disturbed land and some agricultural use since at least the 1940s. Wetland vegetation (such as cattails) is present in the wetland area and the irrigation ditch. Grassy and weedy vegetation occupies the remainder of the site. A prairie dog colony appears to have previously occupied a section of the western portion of the site; however, the burrows did not appear to be active/occupied (they were overgrown and partially collapsed) during the June 2019 site reconnaissance. The vegetative communities on Site 2 could support wildlife species associated with suburban areas in northern Colorado, with wetland species in the central portion of the site.

Site 3

Site 3 includes approximately 10.4 acres of undeveloped, mostly grassy land. Site 3 was agricultural land from at least the 1940s until 2004 with Farmers Ditch crossing the central portion of the site. In 2005, Farmers Ditch was rerouted, infrastructure was added, and the site area was graded in anticipation of development. Site 3 has been vacant grassy land since 2005. The vegetative communities on Site 3 could support limited wildlife species associated with suburban areas in northern Colorado.

Site 4

Site 4 consists of approximately 15 acres of unimproved, cultivated agricultural land. Site 4 has been agricultural land since at least the 1940s. Very little non-agricultural vegetation is present on the site other than a small area of trees and grassy land located at the outfall of the stormwater drainage pipe near the southern site boundary. The vegetative communities on Site 4 could support limited wildlife species associated with suburban areas in northern Colorado.

3.7.2 Threatened and Endangered Species

As part of the preparation of this EA, the USFWS and various state natural resources’ agencies were contacted to identify any potential for the presence of state or federally listed species on or in the vicinity of the Site.

According to the U.S. Fish and Wildlife Service (USFWS) Information for Planning and Conservation (IPaC) internet application, 14 federally listed endangered, threatened, or candidate

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species were identified for the vicinity of the Action Alternative sites. The IPaC reports for the sites are provided in Appendix D. The identified species included three mammals, four birds, two fish, one insect, and five flowering plants. No critical habitats were identified on the Action Alternative sites. In response to the request for input regarding the Proposed Action, USFWS indicated that they had no concerns regarding federally protected species at Sites 1 and 4. USFWS indicated Site 2 contains freshwater emergent wetlands and may contain potential habitat for federally listed species (Preble’s meadow jumping mouse, Ute ladies’-tresses (flowering plant), and western prairie fringed orchid). USFWS indicated Site 3 may also contain potential habitat for these protected species.

Site 3 may have once contained suitable habitat for these species; however, since 2005, when Farmers Ditch was rerouted and Site 3 was graded and prepared for development, no suitable habitat remains at Site 3 for these species. Only Site 2 provides potential suitable habitat for these species. Based on the habitat requirements of the remaining federally protected species listed in the IPaC reports, as identified through the USFWS Environmental Conservation Online System (ECOS), they are unlikely to be present at any of the four sites. Table 1 provides a summary of federally protected species listed in the IPaC reports, their habitat requirements, and the presence of required habitat at the Action Alternative sites.

The USFWS IPaC internet application provides a list of birds protected under the Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act that may occur, nest, or warrant special attention in the four Action Alternative site areas. Ten migratory bird species were identified as being possibly being present on Site 1; thirteen bird species were identified for Site 2; and three bird species were identified for Sites 3 and 4. Based on their association with aquatic habitats or trees, the disturbed nature of the sites, and/or their low probability of presence, the identified birds protected under MBTA are generally unlikely to nest at the sites.

According to the Colorado Department of Natural Resources-Parks and Wildlife (CDNR PW), the construction of the OPC has some potential to impact wildlife at all four of the Action Alternative sites; however, the expected impact is minimal as each of the sites is already currently disturbed by human activity and surrounded mostly by commercial development. CDNR PW indicated they do not anticipate impacts to federally listed threatened or endangered species at any of the sites, including Site 2, as the proposed OPC construction would be outside of the wetlands area. CDNR PW stated any impacts to the wetlands at Site 2 would require additional consideration.

A list of Colorado protected threatened and endangered species was obtained from the CDNR PW website. One amphibian, eight birds, fourteen fish, and eight mammals are protected by the State of Colorado. The CDNR PW website provided information regarding the general range of these species in Colorado and their habitat requirements. Based on this information and the site conditions, two of the Colorado protected species may be present at Site 2 (Preble’s meadow jumping mouse and burrowing owl). No Colorado protected species are likely to be present at Sites 1, 3, or 4.

According to a 2004 Survey of Critical Biological Resources conducted for Larimer County by the Colorado Natural Heritage Program, there are many areas of biological significance in Larimer County. The Fossil Creek Reservoir area (north of Site 2) is listed as an area of general biodiversity interest, largely due to documented bald eagle occurrences and cottonwood trees. The Action Alternative sites were not identified as areas of biodiversity interest.

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Table 1. Federally Listed Species in the Vicinity of the Action Alternative Sites Habitat Present Species Status Habitat at the Sites Mammals Canada lynx Threatened Moist, boreal forests No North American Proposed Large undisturbed areas with deep persistent No wolverine Threatened reliable snow cover, near arctic conditions Well developed riparian habitat with adjacent, Preble’s meadow Site 2 Threatened relatively undisturbed grassland and a nearby jumping mouse only water source Birds Sparsely vegetated sandbars and islands Least tern Endangered No along major rivers Mexican spotted Old-growth or mature forests with complex Threatened No owl structural components Piping plover Threatened Shorelines of lakes, reservoirs, and rivers No Whooping crane Endangered Marshes, shallow lakes, and lagoons No Fish Greenback Threatened Cold water streams and lakes No cutthroat trout Pallid sturgeon Endangered Large rivers No Insects Arapahoe snowfly Candidate Cold, well-oxygenated streams and rivers No Flowering Plants Subirrigated stream deposited soils on level Colorado butterfly or slightly sloping floodplains and drainage Threatened No plant bottoms, stream channels that are periodically disturbed, elevation 5,000-6,400 feet Only found in North Park, Jackson County, North park Endangered Colorado; limited to soil outcrops of the No phacelia Coalmont Formation Moist meadows associated with streams, Ute Site 2 Threatened irrigation canals, wetlands, and lakes, ladies’-tresses only elevation 4,300-6,850 feet Western prairie Unplowed, calcareous prairies and sedge Site 2 Threatened fringed orchid meadows only

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3.7.3 Effects of the Action Alternatives

Sites 1, 3, and 4

Sites 1, 3, and 4 are routinely disturbed (agricultural land) or have been recently graded (Site 3 development preparation activities), are located in commercial areas, contain little or no natural vegetation, and do not contain suitable habitat for federally listed species or state-listed species. Implementation of the Proposed Action at any of these sites would not likely have adverse effects on protected species or their critical habitats. A pre-construction nesting bird survey or timed development (outside the nesting season) would be conducted at the selected site to avoid potential ground-nesting birds protected under the MBTA.

Site 2

Site 2 contains wetlands that provide potentially suitable habitat for the federally protected Preble’s meadow jumping mouse, Ute ladies’-tresses (flowering plant), and western prairie fringed orchid.

The habitat requirements for the western prairie fringed orchid consists of unplowed, calcareous prairies and sedge meadows with a high soil moisture content. The western prairie fringed orchid is dependent on mycorrhizal fungi for seed germination, and limited periodic disturbance by fire, mowing, or grazing. The habitat requirement for the Ute ladies’-tresses consist of moist meadows associated with perennial stream terraces, floodplains, oxbows, seasonally flooded river terraces, subirrigated or spring-fed abandoned stream channels, valley, and lakeshores. In addition, populations have been discovered along irrigation canals, berms, levees, irrigated meadows, excavated gravel pits, roadside barrow pits, reservoirs, and other human-modified wetlands. Site 2 contains suitable habitat for the Ute ladies’-tresses and could possibly contain suitable habitat for the western prairie fringed orchid. Should Site 2 be selected, the site would be assessed by a USFWS-approved surveyor prior site design development. If Ute ladies’-tresses or western prairie fringed orchid were identified at Site 2, consultation with USFWS would be conducted to prevent significant impacts to this species. The OPC design would avoid potential disruption to these protected plants to the extent possible.

The habitat requirements for Preble’s meadow jumping mouse consists of well developed riparian habitat with adjacent, relatively undisturbed grassland communities and a nearby water source. Well developed riparian habitats include a dense combination of grasses, forbs, and shrubs, and a taller shrub and tree canopy may be present. The Preble’s meadow jumping mouse has been found to regularly use uplands at least as far out as 300 feet from the water source. The irrigation ditch located in the central portion of Site 2 contains marginally suitable habitat for Preble’s meadow jumping mouse. If Site 2 is selected, a field survey for Preble’s meadow jumping mouse by a qualified, USFWS-approved surveyor would be conducted prior to site design development. If Site 2 is found to contain Preble’s meadow jumping mouse, consultation with USFWS would be conducted to prevent significant impacts to this species.

A prairie dog colony appears to have previously occupied a section of the western portion of Site 2; however, the burrows did not appear to be active/occupied (they were overgrown and partially collapsed) during the June 2019 site reconnaissance. The City of Fort Collins requires that any prairie dogs inhabiting a site must be relocated or humanely eradicated prior to development. Burrowing owls, protected under the MBTA and a state-listed threatened species, may inhabit prairie dog burrows. Ground disturbance construction activities would be timed to avoid the

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burrowing owl nesting season (March through August), if possible. The prairie dog burrows would be surveyed by a qualified biologist for burrowing owls prior to construction, as required by the City of Fort Collins. If nesting owls are present, ground disturbance would be delayed until the young owls have fully fledged.

According to the City of Fort Collins, an Ecological Characterization Study (ECS) would be required for Site 2 as the site is located within 500 feet of a defined natural habitat (wetlands, aquatic areas, winter raptor concentration area). Buffer zone standards range from 50 to 300 feet for these areas.

Through the implementation of these avoidance and management measures, and mitigation measures if necessary, wildlife and habitat impacts at Site 2 would be less than significant.

VA’s closure of the existing leased Fort Collins MSOC and Loveland CBOC, would have no wildlife and vegetation impacts. These facilities would likely be leased by the owners for other commercial use.

3.7.4 Effects of the No Action Alternative

Under the No Action Alternative, no impacts to biological resources by VA would occur. However, should the Action Alternative sites ultimately be developed by others, impacts similar to those identified under the Proposed Action could occur.

3.8 Noise

Site 1

The existing noise environment around Site 1 is dominated by air traffic (small aircraft and helicopters) from the westerly adjoining Northern Colorado Regional Airport (the main runway is located 1,600 feet west of the site) and vehicle traffic along Interstate 25 (located 1,500 feet east of the site), and Byrd Drive (located to the east of the site). The site is not located within the designated flight path areas for the airport. Minor noise is also associated with the Thunder Mountain Harley-Davidson motorcycle dealership (and associated riding classes) located approximately 600 feet southeast of the site. No other notable noise-generating sources are present in the immediate vicinity of Site 1. In 2006, as part of the master plan updates for the airport, airport noise modeling was conducted using 2003 baseline data and projected noise levels in 2023. Day Night Average Sound Level (DNL) noise contours were developed. The southwestern corner of Site 1 was found to have a DNL of 55 decibels under both scenarios; the remainder of the site had a DNL of less than 55 decibels. The Federal Aviation Administration (FAA) considers a DNL of 65 decibels or less to be compatible with all land uses, including residences, offices and hospitals. The City of Loveland uses a DNL of 55 decibels to restrict land to non-residential uses.

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Site 2

The existing noise environment around Site 2 is dominated by vehicle traffic along East County Road 32 (State Route 392/Carpenter Road), located along the northern site boundary and Interstate 25, located approximately 300 feet east of the site (1,500 feet from the proposed OPC). Minimal noise is associated with traffic along Southwest Frontage Road and air traffic from the Northern Colorado Regional Airport (approximately 1.25 miles southeast of the site). No other notable noise-generating sources are present in the immediate vicinity of Site 2.

Site 3

The existing noise environment around Site 3 is dominated by vehicle traffic along Ronald Reagan Boulevard, located along the southern site boundary. Noise is also associated with traffic along Larimer Parkway (approximately 400 feet west of the site), Union Street (northern site boundary), Trade Street (eastern site boundary), and East Eisenhower Boulevard (US 34), located approximately 600 feet north of the site. No other notable noise-generating sources are present in the immediate vicinity of Site 3.

Site 4

The existing noise environment around Site 4 is dominated by vehicle traffic along Centerra Parkway, located along the eastern site boundary. Other noise generators in the area include air traffic from the Northern Colorado Regional Airport (approximately 1.5 miles northwest of the site) and vehicle traffic from Interstate 25, located approximately 1,600 feet west of the site. No other notable noise-generating sources are present in the immediate vicinity of Site 4.

3.8.1 Sensitive Receptors

Sensitive noise receptors in the vicinity of Site 2 include a residential area located approximately 600 feet southwest of the site. At Site 3, sensitive noise receptors include medical offices located to the north and west of the site, as well as a residential area located to the southwest of the site across Ronald Reagan Boulevard. No sensitive noise receptors are located in the vicinity of Sites 1 and 4.

3.8.2 Effects of the Action Alternatives

The Proposed Action would have short-term impacts to the existing noise environment due to construction activities. Noise generating sources during construction activities would be associated primarily with standard construction equipment and construction equipment transportation. These increased noise levels could directly affect the neighboring areas.

Construction activities generate noise by their very nature and are highly variable, depending on the type, number, and operating schedules of equipment. Construction projects are usually executed in stages, each having its own combination of equipment and noise characteristics and magnitudes. Construction activities are expected to generally be typical of other similar construction projects and would include mobilization, site preparation, excavation, placing foundations, utility development, heavy equipment movement, and paving roadways and parking areas. The most prevalent noise source at typical construction sites is the internal combustion engine. General construction equipment using engines includes, but is not limited to: heavy, medium, and light equipment such as excavators; roller compactors; front-end loaders;

DRAFT ENVIRONMENTAL ASSESSMENT 37 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS AFFECTED ENVIRONMENT/ENVIRONMENTAL CONSEQUENCES bulldozers; graders; backhoes; dump trucks; water trucks; concrete trucks; pump trucks; utility trucks; cranes; and lube, oil, and fuel trucks.

Peak noise levels vary at a given location based on line of sight, topography, vegetation, and atmospheric conditions. In addition, peak noise levels would be variable and intermittent because each piece of equipment would only be operated when needed. However, peak construction noise levels would be considerably higher than existing noise levels. Relatively high peak noise levels in the range of 93 to 108 dBA (decibels, A-weighted scale) would occur on the active construction site, decreasing with distance from the construction areas. Generally speaking, peak noise levels within 50 feet of active construction areas and material transportation routes would most likely be considered “striking” or “very loud”, comparable to peak crowd noise at an indoor sports arena. At approximately 200 feet, peak noise levels would be loud - approximately comparable to a garbage disposal or vacuum cleaner at 10 feet. At 0.25 miles, construction noise levels would generally be quiet enough so as to be considered insignificant, although transient noise levels may be noticeable at times. Table 2 presents peak noise levels that could be expected from a range of construction equipment during proposed construction activities.

Combined peak noise levels, when several loud pieces of equipment are used in a small area at the same time, are expected to occur rarely, if ever, during the project. However, under these circumstances, peak noise levels could exceed 90 dBA within 200 feet of the construction area, depending on equipment being used.

Although noise levels would be quite loud in the immediate area, the intermittent nature of peak construction noise levels would not create the steady noise level conditions for an extended duration that could lead to hearing damage. Construction workers would follow standard federal Occupational Safety and Health Administration requirements to prevent hearing damage.

Areas that could be most affected by noise from construction include those closest to the construction footprint, including the residential area located southwest of Site 2 and the medical offices and residences near Site 3. Indoor noise levels would be expected to be 15-25 decibels lower than outdoor levels. In addition, BMPs (described in Section 5) would be implemented to reduce noise impacts. Direct construction noise impacts would be temporary and less than significant.

Indirect impacts include noise from workers commuting and material transport. Area traffic volumes and noise levels would increase slightly as construction employees commute to and from work at the project area, and delivery and service vehicles (including trucks of various sizes) transit to and from the site. Persons in the project area would experience temporary increases in traffic noise during daytime hours. These effects are not considered significant because they would be temporary, intermittent, and similar to existing traffic noise levels in the area.

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Table 2. Peak Noise Levels Expected from Typical Construction Equipment

Peak Noise Level (dBA, attenuated) Source Distance from Source (feet) 0 50 100 200 400 1,000 1,700 2,500 Heavy Truck 95 84-89 78-93 72-77 66-71 58-63 54-59 50-55 Dump Truck 108 88 82 76 70 62 58 54 Concrete 108 85 79 73 67 59 55 51 Mixer Jackhammer 108 88 82 76 70 62 58 54 Scraper 93 80-89 74-82 68-77 60-71 54-63 50-59 46-55 Bulldozer 107 87-102 81-96 75-90 69-84 61-76 57-72 53-68 Generator 96 76 70 64 58 50 46 42 Crane 104 75-88 69-82 63-76 55-70 49-62 45-48 41-54 Loader 104 73-86 67-80 61-74 55-68 47-60 43-56 39-52 Grader 108 88-91 82-85 76-79 70-73 62-65 58-61 54-57 Pile Driver 105 95 89 83 77 69 65 61 Forklift 100 95 89 83 77 69 65 61

Combined Peak Noise Level (Bulldozer, Jackhammer, Scraper) Distance from Source Combined Peak Noise 50 feet 100 feet 200 feet ¼ mile ½ mile Level 103 97 91 74 68

Source: Tipler 1976 No significant long-term noise impacts are anticipated with the proposed OPC. The OPC would be a quiet medical office facility with operational noise from HVAC systems typical of other comparably sized commercial buildings and grounds maintenance noise (such as lawn mowing). Proposed operational activities at the new OPC would also include vehicle traffic to and from the selected site. The vehicle traffic would not produce excessive noise, is consistent with the existing noise environment of the Action Alternative site areas, and would not produce a significant adverse noise impact on surrounding land uses.

Site 1 is located near Northern Colorado Regional Airport and is affected by noise from airport operations. However, noise modeling for the airport indicates that airport noise levels at the site are compatible with the use of the site as an OPC.

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3.8.3 Effects of the No Action Alternative

Under the No Action Alternative, the noise environment of the Action Alternative sites would not be altered by activities of VA; however, the likely development of the Action Alternative sites by others would produce similar construction and operational noise impacts as identified under the Proposed Action.

3.9 Land Use

Site 1

Site 1 is unimproved vacant land that was recently used for agricultural purposes and is located within the southern portion of a master planned, approximately 142-acre retail and office/business park (Brands West). According to the Loveland Zoning Department, Site 1 is zoned Developing Industrial (I) with a Flexible Zoning Overlay District (FZO). Health care service facilities are a permitted use under the current Developing Industrial zoning designation. The FZO overlay district is intended to stimulate innovative development and promote reinvestment by providing relief from regular land use controls, development intensity limitations, and associated standards.

The neighboring properties to the north and east of Site 1 are also part of the Brands West retail/office park and are also zoned I with the FZO district. The neighboring property to the west (the airport) is currently zoned I and the neighboring property to the south (Western Area Power Administration/U.S. Department of Energy) is not located in the City of Loveland and is zoned Airport (AP) by Larimer County. Zoning designations for Site 1 and surrounding properties are shown on Figure 10.

Site 2

Site 2 is predominantly unimproved grassy vacant land with a few trees around the periphery. The central and eastern portions of the site contain wetlands. According to the Fort Collins Zoning Department, Site 2 is zoned General Commercial District (CG) with a Corridor Activity Center (CAC) overlay district. Hospitals and medical centers/clinics are permitted uses under the current General Commercial District zoning designation. Developments located within the CAC overlay district are subject to the requirements of Fort Collins Land Use Code Division 3.9, which includes additional building restrictions related to aesthetics viewable from the interstate and highway corridors. The City of Fort Collins Zoning Department provided the prospective developer a zoning verification stating the proposed OPC would be a permitted use of Site 2.

The neighboring property to the north of Site 1 (Fossil Creek Reservoir Natural Area) is zoned Public Open Lands District (POL). The neighboring properties to the east (commuter parking lot and interstate) and south (commercial properties) are currently zoned CG. The neighboring properties to the west (mushroom farm and residential neighborhood) are not located within the City of Fort Collins and are zoned Airport (AP) by Larimer County. Zoning designations for Site 2 and surrounding properties are shown on Figure 10.

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Site 3

Site 3 is unimproved grassy vacant land that has previously been graded and prepped for development as part of the 600-acre master planned mixed use 2534 Development. According to the Town of Johnstown Zoning Department, Site 3 is zoned Planned Unit Development Mixed- Use District (PUD-MU). Health care service facilities are not a specifically permitted use under the Planned Unit Development district; however, the PUD-MU district is meant to allow the integration of residential, commercial and industrial development and any permitted, conditional, or accessory use that meets all applicable criteria and regulations is allowed in any zone. According to the Town of Johnstown, medical and offices are permitted uses in the PUD-MU land use district.

The properties surrounding Site 3, also included in the planned 2534 Development area, are also currently zoned PUD-MU. These properties are occupied by medical offices (north and west), a beverage distributor (southeast), residential subdivision (southwest), and unimproved land.

Site 4

Site 4 is unimproved agricultural land located within the northern portion of the 3,000-acre Centerra master planned community. According to the Loveland Zoning Department, Site 4 is zoned Planned Unit Development – Millennium Addition (P-59). Health care service facilities are not a specifically permitted use under the Planned Unit Development; however, any combination of uses may be permitted in a planned unit development so long as the city council determines that such uses are compatible with other proposed planned unit development.

The properties surrounding Site 4 are also located within the Centerra master planned community and are also zoned P-59. These surrounding properties are currently unimproved agricultural land. Zoning designations for Site 4 and surrounding properties are shown on Figure 10.

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POL

I CG I I AP CG

AP

DR SITE 1 P-59 SITE 2

I Developing Industrial CG General Commercial District DR Developing Resource POL Public Open Lands District FZO Flexible Zoning Overlay District AP Airport AP Airport P-59 Planned Unit Development

I DR PUD-MU

PUD-MU P-59

P-59 P-59

PUD-MU SITE 3 SITE 4

PUD-MU Planned Unit Development Mixed-Use I Developing Industrial District DR Developing Resource P-59 Planned Unit Development PREPARED FOR FIGURE 10 U.S. DEPARTMENT OF VETERANS AFFAIRS SITE ZONING MAPS WASHINGTON, DC ENVIRONMENTAL ASSESSMENT PROPOSED OPC TTL PROJECT NO. LARIMER COUNTY, COLORADO 1801701

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3.9.1 Effects of the Action Alternatives

The Action Alternatives would result in negligible land use effects. The proposed OPC would be consistent with local zoning and compatible with surrounding land use at each of the Action Alternative sites. No adverse onsite building function or architecture impacts are anticipated. The proposed OPC would be designed and constructed in accordance with local building codes and zoning ordinances.

VA’s closure of the leased Fort Collins MSOC and Loveland CBOC would have negligible land use impacts. These facilities would likely be leased by others for commercial use.

3.9.2 Effects of the No Action Alternative

Under the No Action Alternative, no land use impacts due to VA's Proposed Action would occur. The Action Alternative sites would likely be developed by others in the future for commercial use in accordance with local zoning regulations. The land use impacts (and associated community benefits) of any future proposed development would depend upon the use proposed.

3.10 Wetlands, Floodplains, and Coastal Zone Management

3.10.1 Wetlands

This section discusses wetlands at or near the Action Alternative sites and surface waters (streams) as they pertain to wetlands. Additional information regarding surface waters is provided in Section 3.6.

Site 1

No surface waters or wetlands were identified at Site 1 or the adjacent properties on the USFWS National Wetland Inventory (NWI) wetland mapper or Colorado Natural Heritage Program Wetlands Inventory (CWI) mapper (Figure 11). In addition, no visual evidence of wetlands or other surface waters was observed at Site 1 during the site reconnaissance or the immediately adjacent areas.

Site 2

According to the USFWS NWI wetland map, PEM1C wetlands are present in the central portion and far northwestern corner (roadside ditch area) of Site 2 (Figure 12). A PEM1C wetland is described as a persistent, emergent, palustrine system (inland wetland that lacks flowing water) that is seasonally flooded. According to the CWI wetland map, the central portion of Site 2 is occupied by a PEMFh wetland and the eastern portion of the site is occupied by a PEMA wetland. A PEMF wetland is described as a semi permanently flooded, emergent, palustrine system. The h modifier indicates the wetland is impounded (that is, created or modified by a barrier or dam that obstructs the outflow of water). A PEMA wetland is described as a temporarily flooded, emergent, palustrine system. The NWI and CWI maps indicate wetland areas are also present on the northerly and southerly adjacent properties. During the June 2019 site reconnaissance, wetlands were observed at the site in areas that generally correlated with those depicted on the CWI map. A concrete wall and spillway were observed beneath East County Road 32 that separated the site wetlands from the wetlands on the northern adjoining property located beyond East County Road 32 (Fossil Creek Reservoir Natural Area).

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In addition to the wetlands, a north-south oriented irrigation ditch was observed in the central portion of the site. The irrigation ditch is located at the approximate western boundary of the wetland depicted on the NWI map (Figure 12).

Site 3

Farmers Ditch is depicted at Site 3 on the USFWS NWI wetland map (Figure 13). As previously discussed, Farmers Ditch has been rerouted and no longer openly crosses Site 3. The ditch is located in a below grade pipe along the northern site boundary. An open segment of the ditch is located east of the site, across Trade Street. No wetlands are depicted on or adjacent to the site on the CWI map. No visual evidence of wetlands or other surface waters was observed at Site 3. Approximately 400 feet south of Site 3 is a stormwater detention pond (not a regulated wetland). No other surface waters or wetlands were identified in the areas immediately adjacent to Site 3.

Site 4

No surface waters or wetlands were identified at Site 4 on the USFWS NWI wetland map or CWI map (Figure 14). In addition, no visual evidence of wetlands or other surface waters was observed at Site 4. A stormwater drainage pipeline outfall was observed near the southern site boundary during the June 2019 site reconnaissance. From the outfall, the stormwater drainage ditch flows off-site to the south to a regional stormwater detention pond located approximately 2,000 feet south of the site. The stormwater drainage ditch and associated detention pond are not regulated wetlands. No surface waters or wetlands were identified in the areas immediately adjacent to Site 4.

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US Fish & Wildlife Service National Wetlands Inventory

Colorado Natural Heritage Program Wetlands Inventory

PREPARED FOR FIGURE 11 U.S. DEPARTMENT OF VETERANS SITE 1 AFFAIRS FEDERAL AND STATE WETLANDS MAPS WASHINGTON, DC ENVIRONMENTAL ASSESSMENT PROPOSED OPC TTL PROJECT NO. LARIMER COUNTY, COLORADO 1801701

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US Fish & Wildlife Service National Wetlands Inventory

Colorado Natural Heritage Program Wetlands Inventory

PREPARED FOR FIGURE 12 U.S. DEPARTMENT OF VETERANS SITE 2 AFFAIRS FEDERAL AND STATE WETLANDS MAPS WASHINGTON, DC ENVIRONMENTAL ASSESSMENT PROPOSED OPC TTL PROJECT NO. LARIMER COUNTY, COLORADO 1801701

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US Fish & Wildlife Service National Wetlands Inventory

Colorado Natural Heritage Program Wetlands Inventory

PREPARED FOR FIGURE 13 U.S. DEPARTMENT OF VETERANS SITE 3 AFFAIRS FEDERAL AND STATE WETLANDS MAPS WASHINGTON, DC ENVIRONMENTAL ASSESSMENT PROPOSED OPC TTL PROJECT NO. LARIMER COUNTY, COLORADO 1801701

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US Fish & Wildlife Service National Wetlands Inventory

Colorado Natural Heritage Program Wetlands Inventory

PREPARED FOR FIGURE 14 U.S. DEPARTMENT OF VETERANS SITE 4 AFFAIRS FEDERAL AND STATE WETLANDS MAPS WASHINGTON, DC ENVIRONMENTAL ASSESSMENT PROPOSED OPC TTL PROJECT NO. LARIMER COUNTY, COLORADO 1801701

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3.10.2 Floodplains

Site 1

According to available Federal Emergency Management Agency (FEMA) floodplain maps (Figure 15), Site 1 is depicted as located in an area of minimal flood hazard (Zone X) and is not located within the 100-year or 500-year floodplains. None of the areas surrounding Site 1 are located in the 100-year or 500-year floodplains.

Site 2

According to available FEMA floodplain maps (Figure 15), Site 2 is depicted as located in an area of minimal flood hazard (Zone X) and is not located within the 100-year or 500-year floodplains. None of the areas surrounding Site 2 are located in the 100-year or 500-year floodplains.

Site 3

According to available FEMA floodplain maps (Figure 15), Site 3 is depicted as located in an area of minimal flood hazard (Zone X) and is not located within the 100-year or 500-year floodplains. None of the areas surrounding Site 3 are located in the 100-year or 500-year floodplains.

Site 4

According to available FEMA floodplain maps (Figure 15), Site 4 is depicted as located in an area of minimal flood hazard (Zone X) and is not located within the 100-year or 500-year floodplains. None of the areas surrounding Site 4 are located in the 100-year or 500-year floodplains.

3.10.3 Coastal Zone

The Coastal Zone Management Act (CZMA) was promulgated to control nonpoint pollution sources that affect coastal water quality. The CZMA of 1990, as amended (16 USC 1451 et seq.) encourages states to preserve, protect, develop, and where possible, restore or enhance valuable natural coastal resources such as wetlands, floodplains, estuaries, beaches, dunes, barrier islands, and coral reefs, as well as the fish and wildlife using those habitats.

According to the National Oceanic and Atmospheric Association, there are no designated coastal zones in Colorado.

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SITE 1 SITE 2

SITE 3 SITE 4

PREPARED FOR FIGURE 15 U.S. DEPARTMENT OF VETERANS AFFAIRS SITE FLOODPLAIN MAPS WASHINGTON, DC ENVIRONMENTAL ASSESSMENT PROPOSED OPC TTL PROJECT NO. LARIMER COUNTY, COLORADO 1801701

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3.10.4 Effects of the Action Alternatives

Sites 1, 3, and 4

Implementation of the Proposed Action at Sites 1, 3, and 4 would not impact wetlands, floodplains, or coastal zones.

Site 2

Implementation of the Proposed Action at Site 2 would not result in floodplain or coastal zone impacts. Wetlands that are likely considered jurisdictional waters of the U.S. by the USACE are present in the central and eastern portions of Site 2. If Site 2 is selected, a wetlands delineation would be conducted to define the extents of the wetlands. The proposed OPC building and parking areas would be located in the western portions of the site and would maintain an undeveloped green space between the development area and the delineated wetlands. The City of Fort Collins requires a 100-foot buffer around wetlands. It is not anticipated that the OPC development would impact the wetlands. However, if during site design it is found that wetlands cannot be avoided, VA’s developer would consult with and obtain all necessary permits from USACE (Clean Water Act Section 404 permit) and CDPHE (Clean Water Act Section 401 permit). Impacted wetland areas, if any, are anticipated to be small. By following the permit requirements and implementing general BMPs, as described in Section 5, impacts to wetlands would be less than significant.

VA’s closure of the existing leased Fort Collins MSOC and Loveland CBOC would have no wetland, floodplain, or coastal zone impacts.

3.10.5 Effects of the No Action Alternative

Under the No Action Alternative, no impacts to wetlands, floodplains, or coastal zones would occur.

3.11 Socioeconomics

The following subsections identify and describe the socioeconomic environment of the City of Fort Collins (Site 2), the City of Loveland (Sites 1 and 4), the Town of Johnstown (Site 3), Larimer County, and the State of Colorado. Presented data provide an understanding of the socioeconomic factors that have developed the area. Socioeconomic areas of discussion include the local demographics of the area, regional and local economy, local housing, and local recreation activities. Data used in preparing this section were collected from the 2010 Census of Population and Housing (U.S. Census Bureau), subsequent U.S. Census Bureau data, and the U.S. Department of Commerce Bureau of Economic Analysis (BEA).

3.11.1 Demographics

The City of Fort Collins’ estimated population in 2017 was 159,150 residents. The City of Loveland’s estimated population in 2017 was 74,125 residents. The Town of Johnstown’s estimated population in 2017 was 14,386 residents. Larimer County’s estimated population in 2017 was 330,976 residents. The estimated population total for Colorado in 2017 was 5,436,519 residents. The City of Fort Collins, City of Loveland, Town of Johnstown, and Larimer County, have lower minority populations than that of the State of Colorado as a whole (Table 3). Minority population rates specific to each Action Alternative site area are discussed in Section 3.16

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(Environmental Justice). High school graduation rates are generally similar for the City of Fort Collins, City of Loveland, Town of Johnstown, and Larimer County, and are slightly higher than the State of Colorado as a whole.

Table 3. Demographic Data for Fort Collins, Loveland, Johnstown, Larimer County, and Colorado All Population Population High School Individuals Under 18 Over 65 Minority Veterans Graduates Area (2017 Age Years Age Years (2017) (2017) (2017) Estimate) (2017) (2017) Colorado 5,436,519 23.0% 13.0% 15.8% 91.1% 376,336 Larimer County 330,976 20.3% 14.2% 8.8% 95.8% 20,770 Fort Collins 159,150 19.1% 10.1% 11.0% 96.4% 7,740 Loveland 74,125 21.8% 17.8% 7.0% 95.4% 5,838 Johnstown 14,386 27.2% 12.4% 7.9% 95.7% 1,020

Sources: U.S. Census Bureau, 2010 Census, Profile of General Demographic Characteristics, 2013-2017.

3.11.2 Employment and Income

The City of Loveland, City of Fort Collins, Larimer County, and the State of Colorado have similar median household incomes (Table 4). The Town of Johnstown has a notably higher median household income. The City of Fort Collins has a higher population below the poverty level than Larimer County and the State of Colorado as a whole. The City of Loveland and Town of Johnstown have lower populations below the poverty level than Larimer County and the State of Colorado. Household incomes specific to each Action Alternative site area are discussed in Section 3.16.

Table 4. Regional Income for Fort Collins, Loveland, Johnstown, Larimer County, and Colorado

Median Unemployment Number of Population Below Household Rate Area Households Poverty Level Income April 2019 Colorado 2,082,531 $65,458 11.5% 3.4% Larimer County 130,502 $64,980 12.4% 2.3% Fort Collins 61,532 $60,110 17.0% 2.3% Loveland 30,724 $61,133 8.7% 2.3% Johnstown 4,955 $85,339 1.5% No data

Sources: U.S. Census Bureau, 2010 Census, Profile of General Demographic Characteristics, 2013-2017. U.S. Department of Labor, Bureau of Labor Statistics.

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3.11.3 Protection of Children

Because children may suffer disproportionately from environmental health risks and safety risks, EO 13045, Protection of Children From Environmental Health Risks and Safety Risks, was introduced in 1997 to prioritize the identification and assessment of environmental health risks and safety risks that may affect children and to ensure that federal agencies’ policies, programs, activities, and standards address environmental risks and safety risks to children. This section identifies the distribution of children and locations where numbers of children may be proportionately high (for example, schools, childcare centers, and family housing) in areas potentially affected by the Proposed Action.

Children are not regularly present at any of the Action Alternative sites. Children may be present in the off-site residential areas located near Sites 2 and 3. No schools or playgrounds are located in the immediate area of any of the Action Alternative sites.

3.11.4 Commuting Patterns

Residents of the City of Fort Collins, City of Loveland, and Town of Johnstown largely depend on personal automobiles for transportation to and from work. Other methods of transit include carpooling, public transportation (Fort Collins and Loveland) and walking. In 2017, the average commuting time was approximately 19.6 minutes in Fort Collins, approximately 24.3 minutes in Loveland, and approximately 32 minutes in Johnstown.

3.11.5 Effects of the Action Alternatives

The Action Alternatives are anticipated to result in short-term, direct, beneficial socioeconomic impacts to local employment and personal income. Construction of the proposed new OPC would provide additional temporary construction jobs in the private sector, thus providing short-term socioeconomic benefit to the selected site area.

The Proposed Action would result in significant long-term beneficial health impacts by providing a new OPC that would enhance the health care provided to regional U.S. Veterans.

No adverse health or safety risks to children are anticipated to result from construction or operation of the new OPC. Children are not regularly present at the Action Alternative sites. In addition, once operational, children would only be present at the OPC as visitors; all Veterans are above the age of 18. Construction areas would be secured to prevent unauthorized access by children from the nearby residential areas. The construction contractor would limit and control construction dust and noise as discussed in Section 5, thereby minimizing adverse effects to children in the area.

VA’s closure of the existing leased Fort Collins MSOC and Loveland CBOC would have negligible socioeconomic impacts. These facilities would likely be leased by other for other commercial use.

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3.11.6 Effects of the No Action Alternative

The No Action Alternative would involve no construction and result in no increased short- or long- term economic benefit due to VA's action. The Action Alternative sites would likely be developed in the future by others for commercial use in accordance with local zoning. The socioeconomic impacts of any future developments would depend on the proposed use.

Most importantly, the inability of VA to provide adequate medical facilities commensurate with the current and anticipated future needs would result in a significant adverse, long-term, direct impact to U.S. Veterans in the region.

3.12 Community Services

Sites 1, 3, and 4 are located in the Thompson School District, which includes Loveland and the surrounding areas. Site 2 is located in the Poudre School District, which includes Fort Collins and the surrounding area.

Resurrection Christian High School is located approximately 2,250 feet northeast of Site 4. No additional schools were identified within one mile of Site 4. No community schools were identified within one mile of Sites 1-3 (Google Earth 2019). Colorado Christian University – Loveland Center is located approximately 3,850 feet southeast of Site 1 and approximately 1,450 feet west- northwest of Site 4.

The Loveland Fire Department provides fire protection to Sites 1, 3 and 4 and the Windsor Fire Department provides fire protection service to Site 2 (Loveland Fire Department 2019 and Windsor Fire Department 2019). The Poudre Fire Authority has also committed to providing public fire protection services to Site 2, based on developer information. Thompson Valley Emergency Medical Services provides emergency medical services to all of the Action Alternative sites and their vicinities (Thompson Valley Emergency Medical Services 2019). The City of Loveland provides police service to Sites 1 and 4, the City of Fort Collins provides police service to Site 2, and the Town of Johnstown provides police service to Site 3.

The Colorado Department of Transportation (CDOT), the City of Fort Collins, City of Loveland, and Town of Johnstown, and Larimer County provide maintenance to primary roads and bridges in the vicinity of the Action Alternative sites.

The Fossil Creek Reservoir Natural Area is located north of Site 2 beyond East County Road 32 and the Soaring Vista Natural Area is located approximately 700 feet south of Site 2. There are no developed recreational areas in the immediate vicinity of Sites 1, 3, and 4.

The Medical Center of the Rockies is located approximately 1.5 miles south of Site 1 and approximately 4,600 feet southwest of Site 4. The Northern Colorado Rehabilitation Hospital is located north of Site 3 beyond Union Street. There are no additional hospitals or other major medical facilities located within one mile of the sites.

Public transportation is currently not available to the Action Alternative sites, but is provided to the site areas. Public transportation in the vicinity of Sites 1, 3, and 4 is provided by the City of Loveland Transit (COLT) system. Public transportation in the vicinity of Site 2 is provided by Transfort. Additional information regarding public transportation in the site vicinities is provided in Section 3.14.

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3.12.1 Effects of the Action Alternatives

No significant additional load is expected to be placed on the local fire or police departments as the result of implementing the Proposed Action at the chosen Action Alternative site. Coordination with Transfort and COLT representatives may expand bus services to include a new bus stop at the OPC. Increased use of other public or community services as a result of the proposed new OPC is not expected. As such, the Proposed Action is expected to have a negligible impact on local public services.

Site 2 is located south of the Fossil Creek Reservoir Natural Area (across Carpenter Road). The Fort Collins Land Use Code requires development buffers for natural habitats and features. These buffers would be included in the site design. The Fort Collins Natural Areas Department indicated they would like to see a trail connection from Soaring Vista Natural Area (south of Site 2) to Fossil Creek Reservoir (north of Site 2), with an underpass beneath Carpenter Road (East County Road 32/State Route 392) in the site vicinity. VA would not be responsible for constructing the trail or underpass; however, the City of Fort Collins would like VA to provide a trail easement if it is determined the trail would cross through the site. With coordination between the VA developer and the City of Fort Collins, these plans could be incorporated into the project design for Site 2. Coordination with the City of Fort Collins to incorporate this trail segment into the design plans is expected to have a net positive impact on local public services.

VA’s closure of the leased Fort Collins MSOC and Loveland CBOC, which would be replaced by the larger, centralized, proposed OPC, would have negligible community service impacts.

3.12.2 Effects of the No Action Alternative

Under the No Action Alternative, no construction by VA’s selected developer would occur and no impacts to community services would be anticipated. Should the Action Alternative sites be developed in the future by others, community service impacts may occur, depending on the use.

3.13 Solid Waste and Hazardous Materials

Hazardous and toxic materials or substances are generally defined as materials or substances that pose a risk (through either physical or chemical reactions) to human health or the environment.

Site 1

A Phase I Environmental Site Assessment (Phase I ESA) was conducted for a 106-acre tract of undeveloped land including Site 1 by Paragon Consulting Group, Inc. in September 2006. The Phase I ESA indicated that Site 1 had been undeveloped and/or agricultural land since at least the 1940s. The Phase I ESA did not identify any environmental concerns or recognized environmental conditions (RECs) in association with Site 1. Based on a review of recent aerial photographs and the June 2019 site reconnaissance, Site 1 has not substantially changed since the 2006 Phase I ESA.

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Site 2

A review of historic aerial photographs and topographic maps indicates Site 2 has been undeveloped with areas of disturbed land and some agricultural use since at least the 1940s. Site 2 currently contains grassy land in the eastern portion, wetlands in the central and eastern portions that appear to be associated with Fossil Creek Reservoir located north of East County Road 32, and vacant grassy land in the western portion. The western portion of the site was observed to have an area containing soil piles and various building debris, including metal siding, ductwork, and plates, railroad ties, steel beams, wood pallets and other wood/brush pile debris, concrete pieces, and various other metal debris during the June 2019 site reconnaissance. No containers of petroleum or hazardous substances, staining, or unusual odors were noted in the vicinity of the soil piles or various debris. Based on aerial photographs, this area has contained debris and soil piles since at least the late 1990s.

Site 3

A Phase I ESA was conducted for Site 3 by Paragon Consulting Group, Inc. in October 2018. The Phase I ESA indicated the site has been undeveloped and/or agricultural land since at least 1902 and is currently vacant grassy land. The Phase I ESA did not identify any environmental concerns or RECs in association with Site 3.

Site 4

A Phase I ESA was conducted for a 168-acre tract of land including Site 4 by Ecological Resource Consultants, Inc. in October 2018. The Phase I ESA indicated that the site has been undeveloped and/or agricultural land since at least 1902 and is currently cultivated agricultural land. The Phase I ESA did not identify any environmental concerns or RECs in association with Site 4.

3.13.1 Effects of the Action Alternatives

The Proposed Action would result in short-term, less-than-significant adverse impacts due to the increased presence and use of petroleum and hazardous substances during construction. An increase in construction vehicle traffic would increase the likelihood for release of vehicle operating fluids (such as oil, diesel, gasoline, and antifreeze) and maintenance materials. As such, a less-than-significant, direct, short-term adverse impact is possible. Implementation of standard construction BMPs would serve to ensure this impact is further minimized.

No significant adverse long-term impacts during operation of the OPC are anticipated. Long-term operational solid and hazardous materials and medical wastes would be managed in accordance with VA's solid and hazardous materials SOPs and applicable federal and state laws. Wastes would be collected and properly disposed of licensed, contracted transportation and disposal companies.

The Proposed Action would not result in a substantial increase in the generation of solid or hazardous wastes, increase the exposure of persons to hazardous or toxic substances, increase the presence of hazardous or toxic materials in the environment, or place substantial restrictions on property use due to hazardous waste, materials, or site remediation. Based on the Phase I ESA information and the former undeveloped/agricultural use of Sites 1, 3, and 4, no contamination is known or likely to be present at any of these sites. Soil piles and building debris have been dumped on the western portion of Site 2 since at least the 1990s. The soil piles and

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debris at Site 2 would be removed from the site and properly disposed of during development. Although no petroleum or hazardous substances are known to be present in the soil piles, construction workers would be informed of the potential for contaminants in the soil and the need to exercise care in handling the soil.

VA’s closure of the leased Fort Collins MSOC and Loveland CBOC would have no solid waste and hazardous materials impacts.

3.13.2 Effects of the No Action Alternative

Under the No Action Alternative, no construction by VA’s developer would occur and no petroleum and hazardous substances impacts associated with the Proposed Action would occur. Should the Action Alternative sites be developed in the future by others, similar short-term and long-term solid waste and hazardous materials impacts as realized under the Proposed Action could occur, depending upon the use.

3.14 Transportation and Parking

Traffic in the vicinity of the Action Alternative sites is regulated by CDOT, Larimer County, the Cities of Fort Collins and Loveland, and the Town of Johnstown.

Public transportation is currently not available to the Action Alternative sites, but is provided to the site areas. Public transportation in the vicinity of Sites 1, 3, and 4 is provided by the COLT system. Public transportation in the vicinity of Site 2 is provided by Transfort. The closest bus stop (COLT Route 3) to Site 1 is located approximately 1,300 feet southeast near the intersection of East Cross Roads Boulevard and Byrd Drive. The closest bus stop (Transfort FLEX) to Site 2 is located approximately 4 miles west near the intersection of South College Avenue (US Route 287) and East County Road 32 (State Route 392/Carpenter Road). The closest bus stop (COLT Route 3) to Site 3 is approximately 4,800 feet northwest near the intersection of Sky Pond Drive and Centerra Parkway. The closest bus stop (COLT Route 3) to Site 4 is located approximately 2,900 feet north near the intersection of East Cross Roads Boulevard and Clydesdale Parkway. As part of VA’s contract requirements, the VA developer would provide public transportation to the selected site, either through an extension of the existing public transportation service or a new shuttle service.

Site 1

Primary access to the Site 1 area is provided by Interstate 25, via the East Cross Roads Boulevard exit, located approximately 1,500 feet southeast of the site. Interstate 25 is a 4 to 6 lane divided north–south highway. East Cross Roads Boulevard is an east-west oriented 6-lane arterial roadway. Byrd Drive intersects with East Cross Roads Boulevard approximately 800 feet west of Interstate 25. The Byrd Drive/East Cross Roads Boulevard intersection is full signalized with dedicated turn lanes.

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There is currently no direct access to Site 1. An approximately 500-foot access drive to the site from Byrd Drive would be constructed through an easement as part of the Proposed Action. Byrd Drive is a north-south oriented two-lane roadway with a dedicated center turn lane. Byrd Drive formerly terminated southeast of the site and turned into SW Frontage Road, which turned east and ran parallel to Interstate 25. In 2016, Byrd Drive was extended to the north (east of the site) to Earhart Road and the associated SW Frontage Road between Byrd Drive and Earhart Road was vacated, likely in anticipation of planned development of the area. As no development has yet to be constructed in the area, the Level of Service (LOS1) rating is likely B or better in the Site 1 vicinity. Nearby roads are illustrated on Figures 2 and 4. Refer to Table 5 for roadway information for the Site 1 vicinity.

Table 5. Site 1 Area Roadways Road Average Estimated Route Direction Width Lanes Daily Traffic Level of (feet) (year) Service 3 Byrd Drive North-South 45 (dedicated center turn Not Available B or better lane and 2 bike lanes) East Cross Roads Boulevard 6 (between Byrd East-West 100 13,500 (2006) C or better (plus 2 bike lanes) Drive and the I-25 intersection) AADT Data Sources: CDOT Online Transportation Information System (OTIS) and Larimer County, Colorado Road Information Locator (RIL). Additional Data Sources: TTL Site Reconnaissance, June 5, 2019.

Site 2

Access to Site 2 is currently provided by East County Road 32 (State Route 392/Carpenter Road) northerly adjoining the site and SW Frontage Road easterly adjoining the site. East County Road 32 intersects with Interstate 25 near the northeastern portion of the site, which provides primary access to the site area. East County Road 32 is an east-west oriented two-lane roadway near the western and central portions of the site and becomes a two-lane divided highway with a dedicated left turn lane at the intersection of East County Road 32 and SW Frontage Road. The intersection is fully signalized. SW Frontage Road is a north-south oriented four-lane roadway with dedicated left and right turn lanes at the intersection of East County Road 32 and SW Frontage Road at the northern portion of the site and becomes a two-lane roadway near the southern portion of the site. East County Road 32 and SW Frontage Road have current estimated LOS ratings of C or better in the site vicinity. Nearby roads are illustrated on Figures 2 and 5. Refer to Table 6 for roadway information for the Site 2 vicinity.

1 Level of Service – LOS represents a set of qualitative descriptions of a transportation system’s performance. The Federal Highway Administration Highway Capacity Manual defines levels of service for intersections and highway segments, with ratings that range from A (best) to F (worst). Generally, a LOS of D or higher is considered acceptable by transportation planning agencies.

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Table 6. Site 2 Area Roadways Road Average Estimated Route Direction Width Lanes Daily Traffic Level of (feet) (year) Service East County Road 32 (between 22,579 East-West 30 2 C or better County Road 9 (2018) and Interstate 25) SW Frontage 48 to 2 to 6 North-South Not Available C or better Road 80 (multiple turn lanes) AADT Data Sources: CDOT OTIS and Larimer County, Colorado RIL. Additional Data Sources: TTL Site Reconnaissance, June 5, 2019.

Site 3

Primary access to the vicinity of Site 3 is from Interstate 25 via East Eisenhower Boulevard (US 34) located approximately 600 feet north of the site. Access to Site 3 would primarily be provided by Larimer Parkway, which intersects with East Eisenhower Boulevard approximately 750 feet northwest of the site. The intersection is fully signalized with dedicated turn lanes. Larimer Parkway leads to the northern adjoining Union Street and southerly adjoining Ronald Reagan Boulevard. Trade Street is located east adjoining the site. Primary access to the OPC at Site 3 would be provided by Union Street and Ronald Reagan Boulevard; Trade Street would provide secondary access. Trade Street is a north-south oriented two-lane roadway. Union Street is an east-west oriented two-lane roadway. Ronald Reagan Boulevard is an east-west oriented two- lane roadway with a dedicated center turn lane. All three of these roads were constructed in the mid to late 2000s, in association with the commercial development of the area. Nearby roads are illustrated on Figures 2 and 7. Refer to Table 7 for roadway information for the Site 3 vicinity.

Table 7. Site 3 Area Roadways Road Average Estimated Route Direction Width Lanes Daily Traffic Level of (feet) (year) Service East Eisenhower Boulevard (US 34) 100 to 6 divided 52,000 (between I-25 and East-West C or better 160 (plus 5 turn lanes) (2018) Centerra Parkway) 4 divided (plus 1 turn Larimer Parkway North-South 84 Not Available C or better lane and 2 bike lanes) Ronald Reagan 2 (dedicated center East-West 50 Not Available B or better Boulevard turn lane) Union Street East-West 32 2 Not Available B or better Trade Street North-South 56 2 Not Available B or better AADT Data Sources: CDOT OTIS and Larimer County, Colorado RIL. Additional Data Sources: TTL Site Reconnaissance, June 5, 2019.

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Site 4

Access to Site 4 is currently provided by Centerra Parkway, easterly adjoining the site. Centerra Parkway is a north-south oriented four-lane divided highway. Centerra Parkway intersects with East Cross Roads Boulevard approximately 0.5 miles north of the site and with East Eisenhower Boulevard approximately 1.5 miles south of the site. Both of these intersections are fully signalized with dedicated turn lanes. East Cross Roads Boulevard and East Eisenhower Boulevard both intersect with Interstate 25 approximately 0.5 miles west of Centerra Parkway. Centerra Parkway was constructed in the mid-2000s in anticipation of the planned mixed-use development of the area. Nearby roads are illustrated on Figures 2 and 8. Refer to Table 8 for roadway information for the Site 4 vicinity.

Table 8. Site 4 Area Roadways Road Average Estimated Route Direction Width Lanes Daily Traffic Level of (feet) (year) Service East Eisenhower Boulevard (US 34) 100 to 6 divided 52,000 (between I-25 and East-West C or better 160 (plus 5 turn lanes) (2018) Centerra Parkway) Centerra Parkway North-South 80 4 divided Not Available C or better East Crossroads 6 East-West 100 Not Available C or better Boulevard (plus 2 bike lanes) AADT Data Sources: CDOT OTIS and Larimer County, Colorado RIL. Additional Data Sources: TTL Site Reconnaissance, June 5, 2019.

3.14.1 Effects of the Action Alternatives

Development of the proposed OPC at one of the four Action Alternative sites could have short- term and long-term, direct and indirect, transportation impacts. Construction traffic, consisting of trucks, workers’ personal vehicles, and construction equipment, would increase traffic volumes in the local area, and could cause delays if this occurred during morning and evening peak periods. Installation and connection of utilities within or adjacent to the selected site could also impact local roadways. These activities could result in additional traffic congestion, as well as a potential need to detour traffic around the area during utility work.

During operation, public roadways in the vicinity of the proposed OPC would experience traffic as a result of usage of the OPC. As described in Section 2.2, the OPC would be used Monday through Friday except on federal holidays, and would operate from 7:00 am to 5:00 pm. The OPC would experience approximately 1,000 Veteran, staff, volunteer and other visitor vehicle stops on an average, daily basis, generating a total of approximately 1,000 round-trip vehicle trips per day (2,000 one-way vehicle trips per day). Given the proposed operational use, traffic generated by the Proposed Action would occur throughout the day, Monday through Friday. Patients of the OPC would travel at various times during the day during daylight hours. Staff at the OPC would commute to and from work at peak travel hours (7:00 am and 5:00 pm).

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Traffic associated with the proposed OPC at the selected Action Alternative site would be new to the local area, because the Veterans who would be served by the OPC (and the OPC staff) currently use the existing Fort Collins MSOC and Loveland CBOC facilities. The Fort Collins MSOC is located between 6 and 12 miles from the sites while the Loveland CBOC is located between 1.3 and 4.5 miles from the sites. The Proposed Action would result in a reduction of VA traffic near the existing facilities and an increase in vehicle traffic near the selected OPC site. Overall, miles driven by Veterans and staff would be similar to existing conditions.

The Proposed Action would have no adverse impact on parking. The OPC development would include on-site parking (approximately 550 spaces) adequate to accommodate the projected needs of Veterans and VA staff using the proposed OPC.

Site 1

Primary access to the OPC at Site 1 would be from Byrd Drive from Cross Roads Boulevard. The traffic associated with the proposed OPC (approximately 2,000 one-way vehicle trips per day) would be an increase of approximately 14.8 percent on East Crossroads Boulevard based on traffic data obtained in 2006. VA’s NEPA regulations (38 CFR 26.6(a)(2)(ii)) define a potential significant traffic impact as “an increase in average daily traffic volume of at least 20 percent on access roads to the site or the major roadway network.” The anticipated increased traffic on East Cross Roads Boulevard is below the 20 percent threshold that indicates a potential significant traffic impact. No daily traffic data are available for Byrd Drive. Byrd Drive was extended to the Site 1 area in 2016 in anticipation of future area development and currently operates well below its designed capacity, and would likely be able to fully accommodate the traffic increase associated with the proposed OPC. As such, the transporation impacts on Byrd Drive are anticipated to be less than significant.

Site 2

Primary access to the OPC at Site 2 would be provided by East County Road 32, which currently operates at a good LOS. The traffic associated with the proposed OPC would be an increase of approximately 8.9 percent on East County Road 32, below the 20 percent threshold that indicates a potential significant traffic impact.

Site 3

Primary access to the OPC at Site 3 would be provided by Ronald Reagan Boulevard and Union Street via Larimer Parkway and East Eisenhower Boulevard (US 34). The traffic associated with the proposed OPC would be an increase of approximately 3.8 percent on East Eisenhower Boulevard, below the 20 percent threshold that indicates a potential significant traffic impact. No daily traffic data are available for the remaining vicinity roadways, however, these roads were recently constructed (mid to late 2000s) and were designed to provide roadway capacity for the planned development of the area, currently operate well below their designed capacity, and would likely be able to fully accommodate the traffic increase associated with the proposed OPC. As such, the transportation impacts on the local roads near Site 3 are anticipated to be less than significant.

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Site 4

Primary access to the OPC at Site 4 would be provided by Centerra Parkway from East Eisenhower Boulevard (to the south) and East Cross Roads Boulevard (to the north). The traffic associated with the proposed OPC would be an increase of approximately 3.8 percent on East Eisenhower Boulevard, below the 20 percent threshold that indicates a potential significant traffic impact. No daily traffic data are available for Centerra Parkway or East Cross Roads Boulevard near the site; however, roads in the area were designed to provide sufficient roadway capacity for the planned development of the area, currently operate below their designed capacity, and would likely be able to fully accommodate the increased traffic associated with the proposed OPC. Traffic impacts on roads near Site 4 are anticipated to be less than significant.

All Action Alternatives

The estimated increase in traffic from the proposed OPC development on the major roads near the Action Alternative sites would be below 20 percent, and roads near the sites currently operate at good LOSs (estimated C or better) and would likely be able to accommodate the traffic increase associated with the proposed OPC. The VA developer would work with CDOT, Larimer County, and the City of Fort Collins, City of Loveland, or Town of Johnstown, as applicable, during the OPC design to identify and implement roadway improvements, such as signalization and turn lanes, as necessary, to ensure that there would be no significant traffic impacts. The City of Fort Collins would require a traffic impact study to determine potential impacts and identify any needed mitigation for the Proposed Action at Site 2.

3.14.2 Effects of the No Action Alternative

Under the No Action Alternative, no transportation or parking impacts associated with the Proposed Action would occur. However, should the Action Alternative sites ultimately be developed by others, traffic and parking impacts would occur. The type and magnitude of transportation and parking effects would depend on the future use of the sites.

3.15 Utilities

Basic utilities in the City of Fort Collins, City of Loveland, and Town of Johnstown (water, sewer, natural gas, and electric) are provided by various utility providers. As part of the preparation of this EA, local utility providers were researched and developer-provided information was reviewed to determine the availability of required utilities in the vicinity of the Action Alternative sites. Utility providers to the Action Alternative sites were identifed as follows:

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Site 1

. The City of Loveland Department of Water and Power supplies electricity to the Site 1 vicinity and reported that is has power near the site. . The Fort Collins-Loveland Water District provides potable water services to the Site 1 vicinity and has a 12” PVC waterline in Byrd Drive, approximately 500 feet east of the site. . The South Fort Collins Sanitation District provides sanitary sewer services to the Site 1 vicinity and has a 10” gravity sanitary sewer line that borders Site 1 on the southern and western sides. . CenturyLink, Comcast (Xfinity), DirecTV, and DISH Network, provide telecommunication services to the Site 1 vicinity. . Xcel Energy and Black Hills Energy supply natural gas to the Site 1 vicinity. Site 2

. Xcel Energy supplies electricity services to the Site 2 vicinity. . The Fort Collins-Loveland Water District provides potable water services to the Site 2 vicinity and has a 4” PVC water line located along Carpenter Road (northern site boundary). . The South Fort Collins Sanitation District does not currently provide sanitary sewer services to Site 2 (the nearest available line is located approximately 730 feet west of the site). The site would require inclusion into the sanitation district boundary prior to being provided sanitary wastewater services. The sanitary sewer line extension would be located along Carpenter Road. . CenturyLink, Comcast (Xfinity), DirecTV, and DISH Network, provide telecommunication services to the Site 2 vicinity. . Xcel Energy and Black Hills Energy supply natural gas to the Site 2 vicinity. Site 3

. Xcel Energy supplies electricity to the Site 3 vicinity. Underground electric service is provided to adjacent developments and can be extended to the site. . The Town of Johnstown supplies potable water and sanitary sewer services to the Site 3 vicinity. An 8-inch water main is located along the western site boundary and would service the site. Water mains are also located along the northern, southern, and eastern site boundaries. . CenturyLink, Comcast (Xfinity), DirecTV, and DISH Network, provide telecommunication services to Site 3 vicinity. . Xcel Energy and Black Hills Energy supply natural gas to the Site 3 vicinity.

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Site 4

. The City of Loveland Department of Water and Power supplies electricity, potable water, and sanitary sewer services to the Site 4 vicinity. An underground electrical main, and a 16” PVC water main are located within the Centerra Parkway right-of-way adjacent to the east of the site. . CenturyLink, Comcast (Xfinity), DirecTV, and DISH Network, provide telecommunication services to the Site 4 vicinity. . Xcel Energy and Black Hills Energy supply natural gas to the Site 4 vicinity.

3.15.1 Effects of the Action Alternatives

The proposed OPC would result in an increase in the consumption of utilities, including electricity, natural gas, potable water, and sanitary sewer discharges. All major utility services are available immediately next to or in close proximity to the Action Alternative sites. Stormwater management, as discussed in Section 3.6, would also be required for the Proposed Action.

The proposed OPC is not anticipated to require extraordinary utility needs beyond those of a similarly sized light industrial/commercial operation. Based on preliminary design information provided the prospective developers, adequate utilities likely exist to supply the facility as currently proposed. However, each utility provider would require a review of the detailed final design plans to validate these preliminary findings and to determine connection/extension requirements to service the proposed OPC. No significant utilities impacts are anticipated.

VA’s closure of the leased Fort Collins MSOC and Loveland CBOC would have negligible utility impacts.

3.15.2 Effects of the No Action Alternative

Under the No Action Alternative, no construction by VA’s selected developer would occur and there would be no utility impacts by VA. However, should the Action Alternative sites ultimately be developed by others, impacts similar to those identified under the Proposed Action could occur. The type and magnitude of utility effects would be dependent upon the future use of the Action Alternative sites.

3.16 Environmental Justice

In 1994, EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, was issued to focus attention of federal agencies on human health and environmental conditions in minority and low-income communities and to ensure that disproportionately high and adverse human health or environmental effects on these communities are identified and addressed.

According to the USEPA-developed EJSCREEN (an environmental justice mapping and screening internet application), the Action Alternative sites are located in areas with smaller low- income populations (13 to 22 percent) compared with the State of Colorado as a whole (29 percent). The minority populations in the Action Alternative site areas (10 to 16 percent) are also smaller than that of Colorado as a whole (31 percent).

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3.16.1 Effects of the Action Alternatives

The Proposed Action would have negligible environmental justice effects. The Action Alternative sites are not located in areas with a disproportionately high population of low-income or minority individuals and the Proposed Action would have very little impact on the residents in the area. During construction, effects on nearby residential land uses, such as through noise and dust, would be limited and controlled through BMPs, thereby minimizing adverse effects to populations in the ROI.

Proposed Action construction activities are anticipated to result in short-term, beneficial socioeconomic (and environmental justice) impacts to local employment and personal income in the ROI, as described in Section 3.11.

3.16.2 Effects of the No Action Alternative

Under the No Action Alternative, no development by VA’s developer would occur at the Action Alternative sites and there would be no direct environmental justice effect by VA. However, Veterans in the northern Colorado area, including low-income and minority populations, would continue to be served by undersized, inadequate VA outpatient health care facilities. If the Action Alternative sites were to be developed by others, it would not likely result in adverse environmental justice effects.

3.17 Cumulative Impacts

The CEQ regulations define cumulative impacts as those which “result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions, regardless of what agency (federal or non-federal) or person undertakes such other actions” (40 CFR 1508.7). Cumulative impact analysis captures the effects that result from the Proposed Action in combination with the effects of other actions before, during, or after the Proposed Action in the same geographic area. Because of extensive influences of multiple forces, cumulative effects are the most difficult to analyze.

3.17.1 Effects of the Action Alternatives

The Action Alternative sites are located in the eastern portion of Larimer County along the Interstate 25 corridor in an area with moderate to rapid development.

Site 1

Site 1 is located in a mixed use (commercial, industrial, and agricultural) area in the City of Loveland. Site 1 is located within the southern portion of a master planned, approximately 142- acre retail and office/business park (Brands West). Byrd Drive was extended through the central portion of the planned retail/office park in 2016 and provides access and infrastructure for the retail/office park parcels. The initial development of the office park began in 2017; however, most of the office park remains undeveloped, vacant former agricultural land. It is anticipated that the office park will be developed with retail stores and office/business buildings in the future; however, no specific development plans were identified.

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Site 2

Site 2 is located in a mixed use (commercial, recreational, residential, and agricultural) area in a recently (2010) annexed area of the City of Fort Collins. Future development of currently vacant or agricultural properties along East County Road 32/Carpenter Road and Interstate 25 in the general area of Site 2 is possible and likely; however, no other specific development plans were identified. Additional development in the immediate area of Site 2 is more limited; the large currently undeveloped parcels near the site are preserved natural areas (Fossil Creek Reservoir Natural Area and Soaring Vista Natural Area).

Site 3

Site 3 is located in a mixed use (commercial, light industrial, residential and vacant land) area in the Town of Johnstown. Site 3 is located within the northeastern portion of the 600-acre master planned mixed use 2534 Development area. Construction began in the 2534 Development area in the mid-2000s, which included the installation of roads and utilities for the entire development. Approximately 50 to 75 percent of 2534 Development area has been developed with commercial, office, light industrial, and residential properties. Vacant parcels remain in the area near Site 3 and are primarily planned for light industrial or office and retail use; however, specific development plans for these parcels were not identified.

Site 4

Site 4 is located in a mixed-use (commercial and agricultural) area in the City of Loveland. Site 4 is located in the northern, yet to be developed area of the 3,000-acre Centerra master planned community. The properties surrounding Site 4 are currently unimproved agricultural land. The areas north and west of the site are planned for light industrial use and the area south of the site is planned for mixed office use. Properties east of Centerra Parkway are planned for residential development. It is anticipated that these adjacent areas will be developed as planned; however, no specific development plans were identified.

The Proposed Action would result in impacts to the area as identified throughout Section 3. These include potential impacts to aesthetics (Sites 2 and 3), air quality, soils and geology, hydrology and water quality, wildlife and habitat, noise, wetlands (Site 2), solid waste and hazardous materials, transportation, and utilities. All of these impacts are less than significant and would be further reduced through careful coordination and implementation of general BMPs and management measures, avoidance measures (for potential wildlife and wetlands impacts at Site 2), and compliance with regulatory requirements, as identified in Section 5. Given the nature of the Proposed Action and the nature of the other potential development within the Action Alternative site areas, no significant cumulative adverse effects to any of these resource areas are anticipated. Other potential development in the area of the selected site would be subject to zoning requirements and site plan approval by the applicable municipality, which would serve to maintain and control regional, potentially cumulative impacts.

No significant adverse cumulative impacts to the environment induced by the Proposed Action are anticipated within the region. Close coordination between federal and state agencies, Larimer County, the City of Fort Collins (Site 2), City of Loveland (Sites 1 and 4), or Town of Johnstown (Site 3) and community representatives would serve to manage and control cumulative effects within the region, including managing regional transportation increases with adequate infrastructure. Implementation of local land use and resource management plans would serve to

DRAFT ENVIRONMENTAL ASSESSMENT 66 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS AFFECTED ENVIRONMENT/ENVIRONMENTAL CONSEQUENCES

control the extent of environmental impacts, and continued planning would ensure future socioeconomic conditions maintain the quality of life the area’s residents currently enjoy. Implementation of effective resource management plans and programs should minimize or eliminate any potential cumulative degradation of the natural, cultural, or human environment within the ROI of the Proposed Action.

3.17.2 Effects of the No Action Alternative

Under the No Action Alternative, cumulative impacts would be similar to those identified for the Proposed Action, as the Action Alternative sites would likely be developed for another commercial use. The extent of cumulative effects under the No Action Alternative would depend upon that future use. However, cumulative impacts would not likely be significant, as any new development would be subject to zoning requirements and site plan approval.

3.18 Potential for Generating Substantial Public Controversy

As discussed in Section 4, VA has solicited input from various federal, state, and local government agencies regarding the Proposed Action. Several of these agencies have provided input; none of the input has identified opposition or controversy related to the Proposed Action or the Action Alternatives. VA is publishing and distributing this Draft EA for a 30-day public comment period. Public comments will be considered and addressed in the Final EA.

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SECTION 4: PUBLIC INVOLVEMENT

VA invites public participation in decision-making on new proposals through the NEPA process. Public participation with respect to decision-making on the Proposed Action is guided by the VA NEPA regulations (38 CFR Part 26). Additional guidance is provided in VA’s NEPA Interim Guidance for Projects (VA 2010). Consideration of the views and information of 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, such as minority, low-income, and disadvantaged persons, are urged to participate. Records of agency coordination and public involvement associated with this EA are provided in Appendix A and Appendix E.

4.1 Agency Coordination

Agencies consulted for this EA include:

• U.S. Fish and Wildlife Service • U.S. Environmental Protection Agency • U.S. Army Corps of Engineers • U.S. Department of Agriculture Natural Resource Conservation Service • Colorado Department of Natural Resources (various divisions) • Colorado Department of Public Health & Environment • Colorado Department of Transportation • Colorado State Forest Service • History Colorado Office of Archaeology and Historic Preservation (State Historic Preservation Office) • North Front Range Metropolitan Planning Organization • Larimer County (various departments) • City of Fort Collins (various departments) • Town of Johnstown (various departments) • City of Loveland (various departments)

Responses were received from USACE, USFWS, CDNR – Division of Water Resources (DWR), CDNR PW, CDOT, Larimer County Engineering Department (LCED), Fort Collins Community Development and Neighborhood Services Department, Fort Collins-Loveland Water District (FCLWD)/South Fort Collins Sanitation District (SFCSD), Johnstown Planning and Development Department (JPDD), Loveland Parks and Recreation Department (LPRD), and Loveland Water and Power (LWP). Input provided by these agencies is addressed in the appropriate resource sub-sections of Section 3. Written correspondence from the agencies is provided in Appendix A. The following summarizes that input, which VA used to focus this EA’s analysis:

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• USACE provided generic information regarding waters of the U.S. and Section 404 of the Clean Water Act permit requirements and stated that they should be notified if waters of the U.S. would be impacted (through dredging, filling, or excavation) as a result of the Proposed Action.

• USFWS indicated they had no concerns regarding Sites 1 and 4. The USFWS indicated Site 2 contains freshwater emergent wetlands and may contain potential habitat for three federally listed threatened species (Preble’s meadow jumping mouse, Ute ladie’s-tresses, and western prairie fringed orchid). USFWS indicated Site 3 may also contain potential habitat for these protected species. Site 3 may have once contained suitable habitat for these water-dependent protected species; however, since 2005, when Farmers Ditch was rerouted and Site 3 was graded and prepared for development, no suitable habitat remains at Site 3 for these species. USFWS noted that VA is required to make a determination of effect for listed species and submit the determination to USFWS for concurrence if the determination is “may affect – is not likely to adversely affect” or “may affect – is likely to adversely affect.” USFWS stated that once a site has been selected and VA makes its determination, consultation with USFWS can be initiated, if needed.

• CDNR – DWR indicated there are no records of any permitted wells located on any of the four proposed sites. The decreed point of diversion for the Gerrard Seepage Ditch No. 1 (WDID 0400787) is located within Site 3. CDNR-DWR noted the Farmers Irrigation Canal (WDID 0500519) previously crossed a portion of Site 3, but has since been re-routed. CDNR – DWR did not have record of any other decreed water rights located on any of the proposed sites.

CDNR-DWR indicated if the proposed OPC is developed with on-site stormwater retention, the detention pond must be operated solely for stormwater management, meet specific infiltration rates after rainfall events, and be subject to oversight by a governmental entity (that is, required as part of a permitting process). A detention pond must operate passively, not expose groundwater, and not subject the storm water runoff to any active treatment process. If the proposed on-site stormwater retention facility does not meet these criteria, it will be required to make replacements for evaporation.

• CDNR PW indicated the construction of the OPC has some potential to impact wildlife at all four of the proposed sites; however, the expected impact is minimal as each of the sites is already currently disturbed by human activity and is surrounded by mostly commercial development. CDNR PW indicated they did not anticipate impacts to federally listed threatened or endangered species at any of the sites. Site 2 was noted to have wetlands on the property, but construction of the OPC would take place outside of the wetland area. CDNR PW stated any impacts to the wetlands at Site 2 would require additional consideration. CDNR PW also noted that each site has the potential to experience conflicts with Canada goose populations (especially Site 4). Plans for Site 4 should take into consideration landscaping choices and mitigation measures to avoid prolonged use of lawns and landscaping by geese that may lead to conflict and damage.

• CDOT provided links to environmental studies conducted by CDOT in the vicinity of the proposed OPC sites. Information from these studies was included in this EA, where applicable.

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• LCED indicated the four sites are not within unincorporated Larimer County and, therefore, are not under their jurisdiction. LCED had no additional comments regarding the Proposed Action.

• Fort Collins Community Development and Neighborhood Services Department provided input from several departments within the City of Fort Collins regarding the proposed development of the OPC at Site 2. This information is summarized below.

LAND USE

Site 2 is within the General Commercial zone district and CAC overlay district. Per the City of Fort Collins Land Use Code, the proposed land use (outpatient clinic) is subject to a Type II Review and decision by the Planning and Zoning Board. The project is subject to an enhanced level of design standards in CAC, including building design, parking, site and landscaping requirements as part of the Fort Collins gateway area.

NATURAL AREAS

Site 2 is located immediately south of the Fossil Creek Reservoir Open Space. The Land Use Code requires that whenever a project abuts a Natural Area, then reasonable public access to that Natural Area is required. The Natural Areas Department would like to see a trail connection from Soaring Vista Natural Area (south of Site 2) to Fossil Creek Reservoir (north of Site 2), which would be located along the north side of Carpenter Road (Hwy 392). Ideally the trail would cross Carpenter Road via underpass within the vicinity of this project location. VA would not be responsible for constructing the trail or underpass; just provide a trail easement if it is determined the trail would cross through the property.

NATURAL RESOURCES

An ECS is required by City of Fort Collins Land Use Code (LUC) Section 3.4.1 as Site 2 is within 500 feet of LUC-defined natural habitats and features (wetlands, aquatic areas, winter raptor concentration area). Buffer zone standards range from 50 to 300 feet for these features. The City of Fort Collins provided additional information regarding the ECS requirements and timing. If trees are impacted, a review of trees shall be conducted by City Forestry and Environmental Planning staff to determine mitigation requirements. The City of Fort Collins noted that Site 2 contains a prairie dog colony. Prairie dog colonies one acre or greater in size are considered special habitat features. The LUC requires that any prairie dogs inhabiting a site must be relocated or humanely eradicated prior to development activities. The City also noted a burrowing owl survey by a qualified wildlife biologist, in accordance with Colorado Parks and Wildlife standards would be required prior to any prairie dog removal and issuance of a Development Construction Permit. The City also noted that projects in the vicinity of large natural habitats and/or natural habitat corridors must be designed to complement the visual context of the natural habitat.

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TRAFFIC

Development of Site 2 would require the payment of a fee for reimbursement for the I25/Hwy 392 Interchange improvement project. A traffic impact study would be required to determine impacts and identify any needed mitigation for the project.

HISTORIC PRESERVATION

There are no known, extant historic resources at Site 2 that would require review under the City ordinance, but due to federal involvement the Proposed Action would constitute an undertaking that requires compliance with Section 106 of the NHPA. If any historic resources are identified through that process, the City of Fort Collins would comment on the findings and mitigation strategies as a consulting party.

ECONOMIC

Site 2 is centrally located for eastern Larimer County, but would be a farther drive for residents of Estes Park and Greeley compared to the other locations. Site 2 does not sit adjacent to a public transit route. This could make it more difficult for households without a car to get to the clinic.

• The FCLWD/SFCSD indicated Site 1 is located within the FCLWD and SFCSD service areas. The FCLWD has a 12” PVC waterline in Byrd Drive, approximately 500 feet east of Site 1. The SFCSD has a 10” gravity sanitary sewer that borders Site 1 on the south and west sides.

The FCLWD/SFCSD indicated Site 2 is located within the FCLWD service area with a 4” PVC line along the northern and eastern sides of the site. Site 2 is not currently within the service area for the SFCSD and would require inclusion into the district boundary prior to providing wastewater service. The nearest SFCSD gravity wastewater connection is approximately 730 feet west of Site 2.

The FCLWD/SFCSD do not provide service to the vicinity of Sites 3 and 4.

• The JPDD indicated Site 3 is located in the PUD-MU zoning district and that medical and offices are permitted uses of this land use designation. The JPDD indicated Site 3 has no known potential environmental concerns, no known surface or groundwater resources, no known threatened or endangered species or critical habitats, no existing parks, natural areas, or wildlife habitats, no affected prime or unique farmland, and no unusual traffic, noise, or socioeconomic concerns. The JPDD indicated the Town of Johnstown has no other significant concerns related to Site 3 and stated the site is located in a rapidly growing area of Northern Colorado with adequate infrastructure and transportation systems.

• The LPRD indicated that none of the four Action Alternative site locations would affect existing or future plans for the LPRD and they have no environmental concerns at this time.

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• LWP indicated they had no record of environmental issues at or near the proposed Action Alternative sites. LWP indicated Sites 1, 2, and 3 are not within the LWP service area and forwarded the information request to the Fort Collins-Loveland Water District/South Fort Collins Sanitation District.

4.2 Native American Consultation

VA consulted with six federally recognized Native American tribes as part of this NEPA process, in accordance with 36 CFR 800.2 and EO 13175, Consultation and Coordination with Indian Tribal Governments, 6 November 2000. These tribes, identified as having possible ancestral ties to the Larimer County area, were invited by VA to participate in the EA process as sovereign nations per EO 13175. Coordination and consultation letters were sent to the tribes in June 2019. Responses, if any, and an example of the letters sent to the Tribes is included in Appendix B. Section 10 contains a list of the Tribes invited to consult. One response received to date, from the Northern Cheyenne Tribe, stated that it appeared the Proposed Action would have no effect.

4.3 Public Review

VA is publishing and distributing this Draft EA for a 30-day public comment period, as announced by a Notice of Availability published in a local newspaper of general circulation (Loveland Reporter-Herald). A copy of the Draft EA is available for public review at a local public library. VA will respond to public comments in the Final EA.

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SECTION 5: MANAGEMENT AND MINIMIZATION MEASURES

This section summarizes the management and minimization measures that are proposed to minimize and maintain potential adverse effects of the Proposed Action at acceptable, less-than- significant levels.

Per established protocols, procedures, and requirements, the VA developer and its construction contractors would implement BMPs and would satisfy all applicable regulatory requirements in association with the design, construction, and operation of the proposed OPC at the selected Action Alternative site. These “management measures” are described in this EA, and are included as components of each of the Action Alternatives. “Management measures” are defined as routine BMPs and/or regulatory compliance measures that are regularly implemented as part of proposed activities, as appropriate, across northern Colorado. In general, implementation of such management measures would maintain impacts at acceptable levels for all resource areas analyzed. These are different from “mitigation measures,” which are defined as project-specific requirements, not routinely implemented as part of development projects, necessary to reduce identified potentially significant adverse environmental impacts to less-than-significant levels.

The routine BMPs, management measures, and avoidance measures summarized in Table 9 would be included by VA’s developer in the selected Action Alternative to minimize and maintain adverse effects at less-than-significant levels.

Table 9. Best Management Practices and Minimization Measures Incorporated into the Proposed Action Technical Best Management Practice/Minimization Measure Resource Area Use vegetative buffers to enhance viewscapes, particularly near adjacent residential properties. Use shielded, downward-facing outdoor lighting. Aesthetics Comply with the City of Fort Collins (Site 2), City of Loveland (Site 1 and Site 4), or Town of Johnstown (Site 3) Code of Ordinances, and associated development standards applicable for the selected site. Comply with I-25 and State Route 392 corridor overlay aesthetics (Site 2 only). Use appropriate dust suppression methods (such as use of water, dust palliative, covers, suspension of earth moving in high wind conditions) during onsite construction activities. Implement measures to reduce diesel particulate matter emissions from construction equipment, such as reducing idling time and using newer Air Quality equipment with emission controls. Stabilize disturbed areas through re-vegetation or mulching if the area would remain inactive for several weeks or longer. Comply with the applicable CDPHE and local air quality regulations. Secure any required minor air emissions permits from CDPHE, as appropriate and prior to construction.

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Table 9. Best Management Practices and Minimization Measures Incorporated into the Proposed Action Technical Best Management Practice/Minimization Measure Resource Area Complete Section 106 consultation and other National Historic Preservation Act requirements, as applicable, for the selected site. Should potentially historic or culturally significant items be discovered during Cultural project construction, the construction contractor would immediately cease work Resources in the area until VA, a qualified archaeologist, the SHPO, and the Tribes are contacted to properly identify and appropriately treat discovered items in accordance with applicable state and federal law(s). Control soil erosion and sedimentation impacts during construction by implementing erosion prevention measures and complying with the CDPHE NPDES permitting process. Implement effective controls per a site‐specific SWPPP. The NPDES permit would require stormwater runoff and erosion Geology, management using BMPs, such as earth berms, vegetative buffers and filter Topography, strips, and spill prevention and management techniques. The construction and Soils contractor would implement the sedimentation and erosion control measures specified in the NPDES permit and the SWPPP to protect surface water quality. Obtain and implement local land disturbance and drainage permits, as applicable. Complete form AD-1006 (Farmland Conversion Impact Rating) in conjunction with USDA NRCS for the selected site (Site 1, 3, or 4 only). Use low impact development practices to the extent practicable, during the OPC design. Control soil erosion and sedimentation impacts during construction by complying Hydrology and with the NPDES permit and the SWPPP. Water Quality Design improvements in accordance with the requirements of EISA Section 438 with respect to stormwater runoff quantity and characteristics. Ensure the design of the OPC includes sufficient on-site stormwater management so as not to adversely affect the water quantity/quality in receiving waters and/or offsite areas. Obtain appropriate permits for any off-site stormwater discharges, as applicable. Prior to site design and development, contract an USFWS-approved surveyor to conduct a field survey of the site for federally protected Ute ladies’-tresses, western prairie fringed orchids, and Preble’s meadow jumping mouse in consultation with the USFWS. If protected species are identified, consult with USFWS to prevent significant impact (Site 2 only). Prior to construction, contract a qualified biologist to relocate prairie dogs, if Wildlife and present, prior to ground disturbance and discourage them from returning to the Habitat area during construction (Site 2 only). Ground disturbing construction activities should be timed to avoid the western burrowing owl nesting season (March through August). Prior to construction, a qualified biologist would survey the prairie dog burrows to ensure that no active western burrowing owl nests would be disturbed. If active nests are encountered, construction activities would be delayed until the owls have fully fledged (Site 2 only).

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Table 9. Best Management Practices and Minimization Measures Incorporated into the Proposed Action Technical Best Management Practice/Minimization Measure Resource Area Construction should be timed to avoid the nesting season of migratory birds protected under the Migratory Bird Treaty Act. If it is not practical to clear the site outside of the nesting season, the selected site would be surveyed by a qualified Wildlife and biologist for occupied ground nests prior to clearing and construction activities. Habitat Native species should be used to the extent practicable when re-vegetating land disturbed by construction to avoid the potential introduction of non-native or invasive species. Comply with the noise control provisions of the ordinances applicable to the selected Action Alternative site. Coordinate proposed construction activities in advance with nearby sensitive receptors. Let the local residents know what operations would be occurring at what times, including when they would start and when they would finish each day. Post signage at the entry points of the selected site providing current construction information, including schedule and activity. Limit, to the extent possible, construction and associated heavy truck traffic to occur between 7:00 a.m. and 7:00 p.m. on Monday through Friday, or during normal, weekday, work hours. Noise Locate stationary operating equipment as far away from sensitive receptors as possible. Select material transportation routes as far away from sensitive receptors as possible. Shut down noise-generating heavy equipment when it is not needed. Maintain equipment per manufacturer’s recommendations to minimize noise generation. Encourage construction personnel to operate equipment in the quietest manner practicable (such as through speed restrictions, retarder brake restrictions, engine speed restrictions). Comply with the applicable zoning regulations and development standards for Land Use the selected site. Wetlands, Delineate wetland areas and design OPC development to avoid the delineated Floodplains, and wetlands. Obtain all necessary permits and approvals from USACE and CDPHE Coastal Zone (CWA Sections 404 and 401 permits), as applicable, for any unavoidable Management wetland impacts (Site 2 only). Socioeconomics None required. Community None required. Services Remove and properly dispose of soil piles and solid waste debris dumped on the site. Inform construction contractors of the potential presence of impacted Solid Waste and soil at the site and ensure that any excavated soil is properly handled (Site 2 Hazardous only). Materials Comply with VA Standard Operating Procedures and applicable federal and state laws governing the use, generation, storage, and transportation of solid waste and hazardous materials.

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Table 9. Best Management Practices and Minimization Measures Incorporated into the Proposed Action Technical Best Management Practice/Minimization Measure Resource Area Work with CDOT, Larimer County, and the applicable local municipality during the OPC design to identify and implement roadway improvements, such as turn lanes and signalization, if necessary. Coordinate with CDOT, Larimer County, and the applicable local community to Transportation ensure that construction and operational traffic are consistent in the planning of and Parking future transportation improvements in this vicinity. Ensure construction activities do not adversely affect traffic flow on local roadways; construction would be timed to avoid peak travel hours. Ensure debris and/or soil is not deposited on local roadways during the construction activities. Submit detailed design plans to each utility provider to determine the specific Utilities connection/extension requirements and implement the necessary requirements. Environmental None required. Justice

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SECTION 6: SUMMARY AND CONCLUSIONS

This Draft EA evaluates the Proposed Action of VA to establish an approximately 75,645 NUSF one or two-story OPC, including required parking (approximately 550 surface parking spaces), and other required site amenities and improvements in Larimer County, Colorado. This EA discusses five alternatives: the implementation of the Proposed Action at one of four Action Alternative sites (Sites 1 through 4) and the No Action Alternative. The EA evaluates possible effects to aesthetics; air quality; cultural resources; geology and soils; hydrology and water quality; wildlife and habitat, including threatened and endangered species; noise; land use; floodplains, wetlands, and coastal zone management; socioeconomics; community services; solid and hazardous materials; transportation and parking; utilities; and environmental justice. Table 10 provides a summary of the potential environmental effects associated with each Action Alternative.

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Table 10. Summary of Site Characteristics and Potential Impacts Associated with the Action Alternatives

Site 2 Site 3 Site 1 Northwest Corner of Ronald Site 4 Technical Southwest Corner of East No Action 4875 Byrd Drive Reagan Boulevard and Centerra Parkway Resource Area County Road 32 and Alternative (Loveland) Southwest Frontage Road Trade Street (Loveland) (Fort Collins) (Johnstown) Approximately 15 acres of Approximately 24 acres of Approximately 10.4 acres of Approximately 15 acres of No Impacts vacant agricultural land unimproved grassy/weedy land graded, grassy land located cultivated agricultural land located within a master with wetlands in eastern-central within a master planned 600- located within a 3,000-acre planned 142-acre retail/office portion of the site (outside of acre mixed-use development master planned community. park. the proposed OPC area. Currently, mostly unimproved development area). Aesthetics Commercial, industrial and Commercial, light industrial agricultural and commercial vacant agricultural area. Commercial and residential and residential area. area. area. Large Fossil Creek Reservoir Natural Area located adjoining to north. No/Negligible Impact Less-than-significant Impacts Less-than-significant Impacts No/Negligible Impact Located in a NAAQS moderate non-attainment area for ozone. Proposed Action emissions are anticipated to be well below de Similar minimis levels for ozone. Short-term impacts due to construction dust and particulate matter (managed through BMPs) and long- vehicle term due to vehicle emissions. emissions Air Quality with current VA facilities

Less-than-significant Impacts No NRHP-listed or eligible No NRHP-listed or eligible Farmer’s Ditch, a historic No NRHP-listed or eligible No Impacts historic properties present at historic properties present at or irrigation channel, formerly historic properties present at or or nor the site. SHPO nor the site. SHPO crossed site, but has been nor the site. SHPO Cultural confirmation pending. confirmation pending. rerouted. No NRHP-listed or confirmation pending. Resources eligible historic properties at the site. SHPO confirmation pending. No/Negligible Impact No/Negligible Impact No/Negligible Impact No/Negligible Impact All sites are mostly level; only minor grading anticipated. All sites contain prime farmland or farmland or local importance soils; No Impacts Geology, however, all sites have been planned and zoned for commercial or light industrial development. Site 2 is located in a designated Topography, and urban area an exempt from FPPA. Soil erosion and sediment impacts would be managed through BMPs. Soils Less-than-significant Impacts

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Table 10. Summary of Site Characteristics and Potential Impacts Associated with the Action Alternatives

Site 2 Site 3 Site 1 Northwest Corner of Ronald Site 4 Technical Southwest Corner of East No Action 4875 Byrd Drive Reagan Boulevard and Centerra Parkway Resource Area County Road 32 and Alternative (Loveland) Southwest Frontage Road Trade Street (Loveland) (Fort Collins) (Johnstown) No surface water on or near Wetland areas located in the No surface water on-site. No natural surface water on or No Impacts the site. eastern and central portions of Farmers Ditch formerly near the site. A piped Stormwater runoff during the site. Irrigation ditch located crossed the central portion of stormwater drain crosses the construction managed through along the west side of the main the site, but was rerouted in western portion of the site and BMPs. OPC would include on- wetland area. OPC would be the mid-2000s and currently discharges to an outfall near site stormwater detention and constructed outside of wetland flows through below grade the southern site boundary. would also use the existing areas. piping along the northern site From the outfall, it flows south regional stormwater Stormwater runoff during boundary. An above ground approximately 2,000 feet to a Hydrology and management system, which construction managed through segment of the ditch is regional stormwater detention Water Quality includes a detention pond BMPs. OPC would include on- located east of the site, pond. approximately 2,300 feet site stormwater across Trade Street. Stormwater runoff during southwest of the site. detention/management. Stormwater runoff during construction managed through construction managed BMPs. Stormwater from the through BMPs. Stormwater OPC would discharge to the from the OPC would flow to existing regional stormwater the regional retention pond management system and located 400 south of the site. detention pond. Less-than-significant Impacts Less-than-significant Impacts Less-than-significant Impacts Less-than-significant Impacts

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Table 10. Summary of Site Characteristics and Potential Impacts Associated with the Action Alternatives

Site 2 Site 3 Site 1 Northwest Corner of Ronald Site 4 Technical Southwest Corner of East No Action 4875 Byrd Drive Reagan Boulevard and Centerra Parkway Resource Area County Road 32 and Alternative (Loveland) Southwest Frontage Road Trade Street (Loveland) (Fort Collins) (Johnstown) Vacant agricultural land in a Unimproved grassy/weedy land Vacant, graded, grassy land Cultivated agricultural land. No Impacts master planned retail/office with wetland areas and an in a master planned mixed No federally protected or state- park. irrigation ditch. Western, use development. protected species likely to be No federally protected or proposed development area, No federally protected or present or affected (confirmed state-protected species likely contains an apparently vacant state-protected species likely by USFWS and CDNR PW). prairie dog colony. to be present or affected to be present or affected (confirmed by USFWS and Freshwater emergent wetlands (confirmed by CDNR PW). CDNR PW). and irrigation ditch provide Former potential habitat for potential habitat for federally Preble’s Meadow Jumping threatened Preble’s Meadow Mouse, Ute Ladies’-tresses Jumping Mouse, Ute Ladies’- and Western Prairie Fringed tresses and Western Prairie Orchid is no longer present at Fringed Orchid. No impacts are the site due to rerouting of anticipated as OPC Farmers Ditch. development would occur

outside of the protected Wildlife and species habitat. Pre- Habitat development species surveys would be conducted to confirm, if Site 2 is selected. Prairie dog burrows provide nesting habitat for state-protected burrowing owls. A burrowing owl survey would be conducted prior to construction. Ground disturbing activities would be timed to avoid impacts to the owls, if present. Less-than-significant Impacts, if appropriate management, Less-than-significant Impacts avoidance and mitigation Less-than-significant Impacts Less-than-significant Impacts measures (if necessary) are implemented

DRAFT ENVIRONMENTAL ASSESSMENT 80 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS SUMMARY AND CONCLUSIONS

Table 10. Summary of Site Characteristics and Potential Impacts Associated with the Action Alternatives

Site 2 Site 3 Site 1 Northwest Corner of Ronald Site 4 Technical Southwest Corner of East No Action 4875 Byrd Drive Reagan Boulevard and Centerra Parkway Resource Area County Road 32 and Alternative (Loveland) Southwest Frontage Road Trade Street (Loveland) (Fort Collins) (Johnstown) Located adjacent to Northern Residential neighborhood Residences located No sensitive noise receptors in No Impacts Colorado Regional Airport. located approximately 600 feet southwest of the site, across the site area. Modeled airport DNL noise southwest of site. Natural area Ronald Reagan Boulevard. Short-term noise impacts levels at the site (55 decibels) located adjoining to north of Short-term noise impacts during OPC development are below FAA guidelines for site. during OPC development activities controlled through all land uses (65 decibels). Short-term noise impacts activities controlled through construction BMPs. Noise Short-term noise impacts during OPC development construction BMPs. Operational impacts minor during OPC development activities controlled through Operational impacts minor associated with vehicle traffic. activities controlled through construction BMPs. associated with vehicle traffic. construction BMPs. Operational impacts minor Operational impacts minor associated with vehicle traffic. associated with vehicle traffic. Less-than-significant Impacts Less-than-significant Impacts Less-than-significant Impacts Less-than-significant Impacts Site is located in a Site is located in a commercial Site is located in a Site is located in a commercial No Impacts commercial, light industrial and residential area. commercial, light industrial and agricultural within a and agricultural area within a Site is zoned CG with a CAC and residential area within a master planned community. master planned retail/office overlay, which allow for master planned mixed-use Site is zoned PUD-P59. Health park. hospitals and medical development. care service facilities are not a Land Use Site is zoned I with a FZO care/clinics. Site is zoned PUD-MU. Per specifically permitted use; overlay, which allow for health the Town of Johnstown, however, any use may be care service facilities. medical centers are permitted permitted with city council uses. approval. No/Negligible Impact No/Negligible Impact No/Negligible Impact No/Negligible Impact

DRAFT ENVIRONMENTAL ASSESSMENT 81 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS SUMMARY AND CONCLUSIONS

Table 10. Summary of Site Characteristics and Potential Impacts Associated with the Action Alternatives

Site 2 Site 3 Site 1 Northwest Corner of Ronald Site 4 Technical Southwest Corner of East No Action 4875 Byrd Drive Reagan Boulevard and Centerra Parkway Resource Area County Road 32 and Alternative (Loveland) Southwest Frontage Road Trade Street (Loveland) (Fort Collins) (Johnstown) No wetlands or floodplains on- Wetlands located in the central No wetlands or floodplains No wetlands or floodplains on- No Impacts site or adjacent properties. and eastern portions of the site. on-site or adjacent properties. site or adjacent properties. Not located in a Coastal If site is selected, extents of Not located in a Coastal Not located in a Coastal Management Zone. wetlands would be delineated. Management Zone. Management Zone. OPC development planned for

Wetlands, area outside of the wetlands, Floodplains, and with a green space buffer, as Coastal Zone required by the City of Fort Management Collins. No floodplains located on-site or adjacent properties and not located in a Coastal Management Zone. No/Negligible Impact Less-than-significant Impacts No/Negligible Impact No/Negligible Impact Minor beneficial impacts to local economy as a result of temporary construction jobs. Inadequate VA medical facilities - adverse Socioeconomics impact to local Veterans Significant beneficial impact to area Veterans seeking health care services. Community services are provided to the site area. Proposed OPC would not put a significant additional load on these services. Community No Impacts Services No/Negligible Impact

DRAFT ENVIRONMENTAL ASSESSMENT 82 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS SUMMARY AND CONCLUSIONS

Table 10. Summary of Site Characteristics and Potential Impacts Associated with the Action Alternatives

Site 2 Site 3 Site 1 Northwest Corner of Ronald Site 4 Technical Southwest Corner of East No Action 4875 Byrd Drive Reagan Boulevard and Centerra Parkway Resource Area County Road 32 and Alternative (Loveland) Southwest Frontage Road Trade Street (Loveland) (Fort Collins) (Johnstown) Based on Phase I ESA and Soil piles and various building Based on Phase I ESA and Based on Phase I ESA and No Impacts former use of the site, no materials have been dumped former use of the site, no former use of the site, no contamination is known or on the site since at least 1990s. contamination is known or contamination is known or likely to be present on the site. Soil pile and debris would be likely to be present on the likely to be present on the site. Solid Waste and Potential impacts during removed prior to construction. site. Potential impacts during Hazardous construction and operation Soil/waste handling would be Potential impacts during construction and operation Materials would be managed through managed through standard construction and operation would be managed through standard BMPs. BMPs and VA SOPs. would be managed through standard BMPs. standard BMPs. Less-than-significant Impacts Less-than-significant Impacts Less-than-significant Impacts Less-than-significant Impacts Estimated additional OPC operational traffic on major roads near the sites would range from 3.8 to 14.8 percent. Local roads near No Impacts Sites 1, 3 and 4 were recently constructed, designed to provide sufficient capacity for the planned development of the site areas, and currently operate below their designed capacity. These roads would likely be able to accommodate the traffic increase Transportation associated with proposed OPC. VA’s selected developer would work with CDOT, Larimer County, and the applicable municipality and Parking during the OPC design to identify and implement roadway improvements, if necessary. Proposed OPC would include adequate on-site parking.

Less-than-significant Impacts Utilities likely adequate for the proposed OPC are already located at or near the sites. No Impacts Utilities Less-than-significant Impacts Sites are not located in low-income or high minority area. No Impacts Environmental Proposed Action would have negligible impact on the residents in the selected site area. Low-income and minority Veterans would Justice benefit from the OPC No/Negligible Impacts

DRAFT ENVIRONMENTAL ASSESSMENT 83 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS LIST OF PREPARERS

SECTION 7: LIST OF PREPARERS

DEPARTMENT OF VETERANS AFFAIRS STAFF

Mr. Michael R. Hayes Realty Specialist CFM, Office of Real Property Department of Veterans Affairs

Ms. Christine Modovsky Environmental Engineer Construction & Facilities Management Department of Veteran Affairs

Mr. Héctor M. Abreu Cintrón, AIC Senior Historic Preservation Specialist CFM, Historic Preservation Office Department of Veterans Affairs

TTL ASSOCIATES, INC. (CONSULTANTS)

YEARS OF NAME ROLE DEGREE EXPERIENCE

PROJECT MANAGER, TECHNICAL B.S. AQUATIC LEAD, TECHNICAL QA/QC REVIEW, ENVIRONMENTS/ ROB J. CLARK 33 PROGRAM MANAGEMENT/PROJECT ENVIRONMENTAL SCIENCE, COORDINATION 1985

SCOPING COORDINATION, RESEARCH AND DATA GATHERING, DOCUMENT PREPARATION, CARRIE HESS B.S. GEOLOGY, 2003 12 AFFECTED ENVIRONMENT, ENVIRONMENTAL IMPACT ANALYSIS, SITE RECONNAISSANCE

DRAFT ENVIRONMENTAL ASSESSMENT 84 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS REFERENCES CITED

SECTION 8: REFERENCES CITED

2010 Census-Urbanized Area Reference Map: Fort Collins, CO, March 2012.

2017 Coordinated Public Transit/Human Services Transportation Plan, NFRMPO, December 2017.

38 CFR Part 26. Environmental Effects of the Department of Veterans Affairs Actions. 1 July 2008.

City of Fort Collins, Colorado, 2019.

City of Loveland, Colorado, 2019.

Class I Cultural Resources Review of a Proposed Community Based Outpatient Clinic in Larimer County, Colorado (Site 2). Logan Simpson. November 15, 2018.

Clean Air Act of 1970 (42 U.S. Code [USC] 7401 et. seq.; 40 CFR Parts 50-87) Section 176(c).

Coal Fields and Resources of Colorado map, CDNR and CGS, 2006.

Colorado Department of Natural Resources, 1974, 2012, and 2019.

Colorado Department of Public Health and Environment, 2019.

Colorado Department of Transportation, 2019.

Colorado Department of Transportation Reevaluation Form, US 34 from US 287 to Larimer County Road 3 Environmental Assessment, CDOT Region 4, Original NEPA Approval Date July 2007, Reevaluation Date May 2017.

Colorado Division of Reclamation, Mining & Safety (DRMS), 2019.

Colorado Geological Survey, 1974, 2012, and 2019.

Colorado Map of Potential Evaporite Dissolution and Evaporite Karst Subsidence Hazards, CDNR and CGS, 2012.

Colorado State Forest Service, 2019.

Colorado State University (CSU), Surface Water Resources, 2019.

Colorado Wetland Information Center, mapping tool, 2019.

Community Risk Assessment and Standards of Cover, 2017.

Congressional Submission for an Outpatient Clinic Lease in Support of the Cheyenne, WY VA Medical Center, 2018.

DRAFT ENVIRONMENTAL ASSESSMENT 85 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS REFERENCES CITED

Council on Environmental Quality. 40 CFR Parts 1500-1508, Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act (NEPA).

Cultural Resources Desktop Review and Letter Report, Loveland VA Outpatient Clinic (Site 4). AK Pioneer Consulting. May 6, 2019.

Cultural Resources Study (Northwest Corner of Ronald Reagan Boulevard and Trade Street) (Site 3). Highland Enterprises, LLC. May 23, 2019.

Debris Flow Susceptibility Map of Larimer County, Colorado, CGS, 2015.

Department of Veterans Affairs, Environmental Compliance Manual. Last updated July 1998.

Department of Veterans Affairs Loveland Lease Proposal Site Cultural Resources Inventory, Larimer County, Colorado (Site 1). A&B Cultural Consultants, LLC. April 2019.

EISA Section 438, Technical Guidance on Implementing the Stormwater Runoff Requirements for Federal Projects under Section 438 of the Energy Independence and Security Act (EISA), 2007.

Environmental Geology, several geologic maps, CDNR and CGS, 1975.

EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low- Income Populations. 1994.

EO 13045, Protection of Children From Environmental Health Risks and Safety Risks. 1997.

EO 13175, Consultation and Coordination with Indian Tribal Governments. 6 November, 2000.

Farmland Protection Policy Act (FPPA) (7 USC 4201, et seq.), 1994.

Federal Emergency Management Agency (FEMA), Flood Insurance Rate Maps, 2019.

Fort Collins Air Quality Plan, May 2011.

Fort Collins-Loveland Water District/South Fort Collins Sanitation District, 2019.

Geologic Map of the Boulder – Fort Collins – Greeley Area, Colorado, USGS, 1978.

Geology of Ground Water Resources in Colorado, An Introduction, Special Publication 4, CDNR and CGS, 1974.

Geotechnical Engineering Report for Pavement Thickness Design, Proposed Byrd Drive Extension, Byrd Drive North of Crossroads Boulevard, Loveland, Colorado (Site 1). Terracon Consultants, Inc. November 9, 2007.

Gerrard Seepage Ditch No. 1 (0400787) water rights permit information, 2019.

Highway Functional Classification Concepts, Criteria, and Procedures, 2013 Edition, U.S. Department of Transportation, Federal Highway Administration.

DRAFT ENVIRONMENTAL ASSESSMENT 86 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS REFERENCES CITED

Johnstown Town of 2017 Drinking Water Quality Report, Calendar Year 2016.

Larimer County, Colorado, 2019.

Larimer County Zoning Districts Map, January 2018.

Loveland Fire Rescue Authority District map, 2019.

Loveland Water and Power Drinking Water Quality Report, 2018.

Loveland Water and Power service area maps, 2019.

Master Plan Update, Fort Collins-Loveland Municipal Airport, 2007.

North Front Range Metropolitan Planning Organization, 2019.

Northern Colorado Water Conservancy District, Cache la Poudre River Watershed and Big Thompson River Watershed, 2019.

Oil and Gas Fields Map of Colorado, Map Series 33, CDNR and CGS, 2002.

Oil and Gas Wells Map of Colorado, Map Series 44, CDNR and CGS, 2015.

Phase I Environmental Site Assessment, 106 Acre Undeveloped Property, North of Crossroads Boulevard and Byrd Drive, Loveland, Colorado (Site 1). Paragon Consulting Group, Inc. September 5, 2006.

Phase I Environmental Site Assessment, Undeveloped Parcels, Southwest of Intersection of Union and Trade Streets, Johnstown, Colorado (Site 3). Paragon Consulting Group, Inc. October 18, 2018.

Phase I Environmental Site Assessment Report, Centerra Parkway Parcel 601, Loveland, Colorado (Site 4). Ecological Resource Consultants, Inc. October 8, 2018.

Prospective site developer information, 2019.

South Platte River Basin district map, date unknown.

Special Publication 26, Subsidence Above Inactive Coal Mines: Information for the Homeowner, State of CDNR, CDRMS, and CGS, dated 1985 and updated 2009.

Survey of Critical Biological Resources, Larimer County, Colorado, Colorado State University, 2004.

Town of Johnstown, Colorado, 2019.

Town of Johnstown Transportation Master Plan, February 2008.

University of Nebraska-Lincoln, Encyclopedia of the Great Plains Physiography, 2011.

DRAFT ENVIRONMENTAL ASSESSMENT 87 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS REFERENCES CITED

U.S. Army Corps of Engineers, 2019.

U.S. Department of Agriculture (USDA) Natural Resource Conservation Service (NRCS), 2019.

U.S. Department of Commerce Bureau of Economic Analysis, 2019.

U.S. Census Bureau. 1990, 2000, and 2010.

U.S. Department of Agriculture, Natural Resources Conservation Service Web Soil Survey, 2019.

U.S. Environmental Protection Agency (USEPA), 2019.

U.S. Environmental Protection Agency (USEPA) National Ambient Air Quality Standards (NAAQS). 2008.

USEPA’s Total Maximum Daily Loads (TMDL) Report (USEPA 2006, Total Maximum Daily Loads, Section 303[d] List).

U.S. Fish and Wildlife Service (USFWS), 2019.

U.S. Geological Survey (USGS), 2019.

USGS, Geohydrology of the shallow aquifers in the Fort Collins-Loveland area, Colorado, 2000.

USGS Topographic maps, Windsor and Loveland Quadrangles, 1950 (photorevised 1969) (Windsor), 1962 (photorevised 1984) (Loveland), and 2016 (Windsor and Loveland).

USFWS National Wetlands Inventory Online Mapper, 2019.

Well log, drinking water, total depth 1,160 feet, Fossil Creek Roadside Park, completed August 20, 1959.

Well log, stock, total depth 142 feet, Loveland, Colorado, completed May 18, 1954.

Zone District Map, Town of Johnstown, 2011.

Zoning District Map, City of Loveland, Colorado, April 2019.

DRAFT ENVIRONMENTAL ASSESSMENT 88 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS REFERENCES CITED

Other Internet Searches and Data (accessed May 2019-July 2019): City of Fort Collins: https://www.fcgov.com/ City of Fort Collins Code of Ordinances: https://www.fcgov.com/cityclerk/codes.php City of Loveland: http://www.cityofloveland.org/ City of Loveland Code of Ordinances: http://www.cityofloveland.org/government/municipal-code Colorado Department of Natural Resources: https://cdnr.us/ Colorado Department of Transportation: https://www.codot.gov/ Colorado Division of Reclamation, Mining & Safety: https://mining.state.co.us/Pages/Home.aspx Colorado Geological Survey: http://coloradogeologicalsurvey.org/ COLT (City of Loveland bus transit): http://www.cityofloveland.org/colt FEMA Flood Hazard Insurance Map: http://msc.fema.gov/portal Larimer County: https://www.larimer.org/ Poudre School District (PSD): http://www.psdschools.org/ Thompson School District (TSD): https://www.thompsonschools.org/ Town of Johnstown: https://www.townofjohnstown.com/ Town of Johnstown Code of Ordinances: https://www.townofjohnstown.com/186/Codes Transfort (Fort Collins Bus Line): http://www.ridetransfort.com National Wetlands Inventory: https://www.fws.gov/wetlands/Data/mapper.html North Front Range Metropolitan Planning Organization: https://nfrmpo.org/air-quality U.S. Army Corps of Engineers: http://www.usace.army.mil U.S. Bureau of Census (2000 and 2010 US Census Data): http://www.census.gov USDA NRCS Web Soil Survey: https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx U.S. Environmental Protection Agency: https://www.epa.gov U.S. Fish and Wildlife Service: https://www.fws.gov U.S. Geological Survey: https://store.usgs.gov/map-locator, https://earthquake.usgs.gov/earthquakes/map/ Various mapping tools: www.maps.google.com, www.google.earth.com, etc.

DRAFT ENVIRONMENTAL ASSESSMENT 89 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS LIST OF ACRONYMS AND ABBREVIATIONS

SECTION 9: LIST OF ACRONYMS AND ABBREVIATIONS

AADT Annual Average Daily Traffic I Developing Industrial ACHP Advisory Council on Historic Preservation IPaC USFWS Information for Planning and amsl above mean sea level Conservation AP Airport district JPDD Johnstown Planning and Development BEA Bureau of Economic Analysis Department bgs below ground surface JPWD Johnstown Public Works Department BMP Best Management Practice LCDNR Larimer County Department of Natural Resources CAA Clean Air Act LCED Larimer County Engineering Department CAAA Clean Air Act Amendments LCPD Larimer County Planning Department CAC Corridor Activity Center overlay district LCRBD Larimer County Road and Bridge Department CBOC Community Based Outpatient Clinic LDSC Loveland Development Services Department CDNR Colorado Department of Natural Resources LPRD Loveland Parks and Recreation Department CDOT Colorado Department of Transportation LPWA Loveland Public Works Authority CDPHE Colorado Department of Public Health and Environment LWP Loveland Water and Power CEQ President’s Council on Environmental Quality LOS Level of Service CFR Code of Federal Regulations LUC Land Use Code CSU Colorado State University MBTA Migratory Bird Treaty Act CWI Colorado Wetlands Inventory MOA Memorandum of Agreement CZMA Coastal Zone Management Act MSOC Multi-Specialty Outpatient Clinic dBA decibels (A-weighted scale) NAAQS National Ambient Air Quality Standards DoD Department of Defense NAGPRA Native American Graves Protection and Repatriation Act DRMS Colorado Division of Reclamation, Mining & Safety NEPA National Environmental Policy Act of 1969 DWR CDNR Division of Water Resources NFRMPO North Front Range Metropolitan Planning Organization EA Environmental Assessment NHPA National Historic Preservation Act ECS Ecological Characterization Study NPDES National Pollutant Discharge Elimination EIS Environmental Impact Statement System EISA Energy Independence and Security Act of NRCS Natural Resource Conservation Service 2007 NRHP National Register of Historic Places EJSCREEN USEPA Environmental Justice Screening Application NUSF Net usable square feet EO Executive Order NWI National Wetlands Inventory ESA Environmental Site Assessment OPC Outpatient Clinic FCED Fort Collins Engineering Department OTIS CDOT Online Transportation Information System FCESD Fort Collins Environmental Services Department POL Public Open Lands district FCNAD Fort Collins Natural Areas Department PSD Poudre School District FCPFD Fort Collins Parks and Forestry Department PUD-MU Planned Unit Development Mixed-Use district FCPZD Fort Collins Planning and Zoning Department PUD P-59 Planned Unit Development Millennium Addition FCSD Fort Collins Streets Department PW CDNR Parks and Wildlife FCTOD Fort Collins Traffic Operations Department REC Recognized Environmental Condition FEMA Federal Emergency Management Agency RIL Larimer County Road Information Locator FONSI Finding of No Significant Impact ROI Radius of Influence FPPA Farmland Protection Policy Act ROW Right-of-way FZO Flexible Zoning overlay district sf square feet GC General Commercial district

DRAFT ENVIRONMENTAL ASSESSMENT 90 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS LIST OF ACRONYMS AND ABBREVIATIONS

SHPO Colorado Office of Archaeology and Historic USACE U.S. Army Corps of Engineers Preservation (State Historic Preservation USC United States Code Office) USDA U.S. Department of Agriculture SWPPP Stormwater Pollution Prevention Plan USEPA U.S. Environmental Protection Agency TSD Thompson School District USFWS U.S. Fish and Wildlife Service TTL TTL Associates, Inc. USGS U.S. Geological Survey U.S. United States VA Department of Veterans Affairs

DRAFT ENVIRONMENTAL ASSESSMENT 91 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS AGENCIES AND INDIVIDUALS CONSULTED

SECTION 10: AGENCIES AND INDIVIDUALS CONSULTED

AGENCIES CONSULTED

U.S. Army Corps of Engineers – Omaha District Colorado Department of Transportation 9307 South Wadsworth Boulevard Region 4 Littleton, Colorado 80128 10601 West 10th Street Greeley, Colorado 80634 USDA Natural Resources Conservation Service Brighton Service Center Colorado State Forest Service 57 W Bromley Lane 5060 Campus Delivery Brighton, Colorado 80601-3025 Fort Collins, Colorado 80523-5060

U.S. Environmental Protection Agency, Region 8 History Colorado 1595 Wynkoop Street Office of Archaeology and Historic Preservation Denver, Colorado 80202-1129 Mr. Steve Turner, State Historic Preservation Officer 1200 Broadway U.S. Fish and Wildlife Service Denver, Colorado 80203 Mountain-Prairie Region Colorado Ecological Services Field Office North Front Range Metropolitan Planning Organization Denver Federal Center 419 Canyon Avenue, Suite 300 P.O. Box 25486 Fort Collins, Colorado 80521 Denver, Colorado 80225-0486 Larimer County Department of Natural Resources Colorado Department of Natural Resources 1800 S. County Road 31 Division of Water Resources Loveland, Colorado 80537 1313 Sherman Street, Suite 821 Denver, Colorado 80203 Larimer County Engineering Department 200 West Oak Street, Suite 3000 Colorado Department of Natural Resources P.O. Box 1190 Division of Water Conservation Fort Collins, Colorado 80522-1190 1313 Sherman Street, Room 718 Denver, Colorado 80203 Larimer County Planning Department 200 W. Oak Street, Third Floor Colorado Department of Natural Resources Fort Collins, Colorado 80521 Parks & Wildlife 1313 Sherman Street, 6th Floor Larimer County Road and Bridge Department Denver, Colorado 80203 2643 Midpoint, Suite C Fort Collins, Colorado 80525 Colorado Department of Natural Resources Parks & Wildlife – Northeast Region Fort Collins Engineering Department 6060 Broadway 281 N. College Denver, Colorado 80216 Fort Collins, Colorado 80524

Colorado Department of Public Health & Environment Fort Collins Environmental Services Department Air Pollution Control Division 222 Laporte Avenue 4300 Cherry Creek Drive South P.O. Box 580 Denver, Colorado 80246 Fort Collins, Colorado 80522-0580

Colorado Department of Public Health & Environment Fort Collins Parks and Forestry Department Hazardous Materials and Waste Management Division 413 South Bryan Avenue 4300 Cherry Creek Drive South Fort Collins, Colorado 80521 HMWMD-B2 Denver, Colorado 80246 Fort Collins Natural Areas Department 1745 Hoffman Mill Road Colorado Department of Public Health & Environment Fort Collins, Colorado 80524 Water Quality Control Division 4300 Cherry Creek Drive South Fort Collins Planning and Zoning Department WQCD-B2 281 N. College Denver, Colorado 80246 Fort Collins, Colorado 80524

DRAFT ENVIRONMENTAL ASSESSMENT 92 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS AGENCIES AND INDIVIDUALS CONSULTED

Fort Collins Streets Department 625 Ninth Street Fort Collins, Colorado 80524

Fort Collins Traffic Operations Department 626 Linden Street Fort Collins, Colorado 80524

Johnstown Public Works Department 450 S. Parish Avenue Johnstown, Colorado 80534

Johnstown Planning and Development Department 450 S. Parish Avenue Johnstown, Colorado 80534

Loveland Development Services Center 410 East 5th Street Loveland, Colorado 80537

Loveland Parks & Recreation Department 500 E. Third Street, Suite 200 Loveland, Colorado 80537

Loveland Public Works Administration 2525 West 1st Street Loveland, Colorado 80537

Loveland Water and Power 200 North Wilson Avenue Loveland, Colorado 80537

DRAFT ENVIRONMENTAL ASSESSMENT 93 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS AGENCIES AND INDIVIDUALS CONSULTED

NATIVE AMERICAN TRIBES CONSULTED

Apache Tribe of Oklahoma Lyman Guy, Chairman P.O. Box 1330 Anadarko, Oklahoma 73005

Arapaho Tribe of the Wind River Reservation, Wyoming Yufna Soldier Wolf, THPO P.O. Box 67 Stevens, Wyoming 82524

Cheyenne and Arapaho Tribes, Oklahoma Max Bear, THPO 200 Wolf Robe Circle Concho, Oklahoma 73022

Comanche Nation, Oklahoma Margaret Murrow, NAGPRA Director 10 SW D Avenue Lawton, Oklahoma 73502

Fort Belknap Indian Community of the Fort Belknap Reservation of Montana Michael Blackwolf, THPO 656 Agency Main Street Harlem, Montana 59526

Northern Cheyenne Tribe of the Northern Cheyenne Indian Reservation, Montana Teanna Limpy, Director THPO P.O. Box 128 Lame Deer, Montana 59043

DRAFT ENVIRONMENTAL ASSESSMENT 94 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS LIST OF ENVIRONMENTAL PERMITS REQUIRED

SECTION 11: LIST OF ENVIRONMENTAL PERMITS REQUIRED

11.1 Regulatory Framework

This EA has been prepared under the provisions of, and in accordance with NEPA, the CEQ Regulations Implementing the Procedural Provisions of NEPA, and VA’s NEPA regulations. In addition, the EA has been prepared as prescribed in VA’s NEPA Interim Guidance for Projects (VA 2010). Federal, state, and local laws and regulations specifically applicable to this Proposed Action are identified, where appropriate, within this EA, and include:

. Endangered Species Act of 1973, as amended (7 USC 136; 16 USC 1531 et seq.).

. Energy Independence Security Act Section 438.

. Executive Order 11988, Floodplain Management (24 May 1977).

. Executive Order 11990, Protection of Wetlands (24 May 1977).

. Executive Order 12898, Environmental Justice (11 February 1994).

. Executive Order 13834, Efficient Federal Operations (17 May 2018).

. Farmland Protection Policy Act (7 USC 4201, et seq.)

. Federal Clean Air Act of 1990 (42 USC 7401 et seq., as amended).

. Federal Clean Water Act (Federal Water Pollution Control Act) of 1948, as amended (1972, 1977) (33 USC 1251 et seq.); Sections 401 and 404.

. Migratory Bird Treaty Act (16 USC 703-712, 3 July 1918; as amended 1936, 1960, 1968, 1969, 1974, 1978, 1986, and 1989).

. Native American Graves Protection and Repatriation Act, as amended (25 USC 3001 et seq.).

. National Historic Preservation Act of 1966, as amended (36 CFR Part 800).

. Colorado Department of Public Health and Environment Air Quality Central Commission Regulations.

. Colorado Department of Public Health and Environment Water Quality Control Division Regulations.

. Fort Collins Code of Ordinances.

. Loveland Code of Ordinances.

DRAFT ENVIRONMENTAL ASSESSMENT 95 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS LIST OF ENVIRONMENTAL PERMITS REQUIRED

. Johnstown Code of Ordinances.

11.2 Environmental Permits Required

In addition to the regulatory framework of NEPA, the CEQ Regulations Implementing the Procedural Provisions of NEPA, VA’s NEPA regulations, and VA’s NEPA Interim Guidance for Projects, the following federal, state, and local environmental permits are required as part of this Proposed Action, and include:

• CDPHE Stormwater Discharge Associated with Construction Activities Permit (NPDES Permit).

• CDPHE Land Disturbance Permit.

• CDPHE Air Pollution Emissions Notice construction permit is required if more than 25 acres of land will be impacted and/or construction will last longer than 6 months.

• Municipal Site Development Permit (Loveland, Fort Collins, or Johnstown, as applicable).

• USACE Clean Water Act Section 404 Permit (Site 2 only, if applicable).

• CDPHE Clean Water Act Section 401 Permit (Site 2 only, if applicable).

DRAFT ENVIRONMENTAL ASSESSMENT 96 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS GLOSSARY

SECTION 12: GLOSSARY

100-Year Flood – A flood event of such magnitude that it appointed by the President, subject to approval by the Senate. occurs, on average, every 100 years; this equates to a one Each member shall be exceptionally qualified to analyze and percent chance of its occurring in a given year. interpret environmental trends, and to appraise programs and activities of the federal government. Members are to be Aesthetics – Pertaining to the quality of human perception of conscious of and responsive to the scientific, economic, natural beauty. social, aesthetic, and cultural needs of the Nation; and to Agricultural land - Cropland, pastures, meadows, and formulate and recommend national policies to promote the planted woodland. improvement of the quality of the environment.

Ambient - The environment as it exists around people, plants, Criteria Pollutants - The CAA of 1970 required the USEPA and structures. to set air quality standards for common and widespread pollutants in order to protect human health and welfare. There Ambient Air Quality Standards - Those standards are six "criteria pollutants": ozone (O3), carbon monoxide established according to the CAA to protect health and (CO), sulfur dioxide (SO2), lead (Pb), nitrogen dioxide (NO2), welfare (AR 200-1). and particulate matter. Aquifer - An underground geological formation containing Cultural Resources - The physical evidence of our Nation's usable amounts of groundwater which can supply wells and heritage. Included are: archaeological sites; historic buildings, springs. structures, and districts; and localities with social significance Asbestos - Incombustible, chemical-resistant, fibrous mineral to the human community. forms of impure magnesium silicate used for fireproofing, Cumulative Impact - The impact on the environment that electrical insulation, building materials, brake linings, and results from the incremental impact of the action when added chemical filters. Asbestos is a carcinogenic substance. to other past, present, and reasonable foreseeable future Attainment Area - Region that meets the National Ambient actions regardless of what agency (federal or non-federal) or Air Quality Standard (NAAQS) for a criteria pollutant under the person undertakes such other actions. Cumulative impacts CAA. can result from individually minor but collectively significant actions taking place over a period of time (40 CFR 1508.7). Bedrock - The solid rock that underlies all soil, sand, clay, gravel and loose material on the earth's surface. Decibel (dB) - A unit of measurement of sound pressure level.

Best Management Practices (BMPs) - Methods, measures, Direct Impact - A direct impact is caused by a Proposed or practices to prevent or reduce the contributions of Action and occurs at the same time and place. pollutants to U.S. waters. Best management practices may be Emission - A release of a pollutant. imposed in addition to, or in the absence of, effluent limitations, standards, or prohibitions (AR 200-1). Endangered Species - Any species which is in danger of extinction throughout all or a significant portion of its range. Commercial land use – Land use that includes private and public businesses (retail, wholesale, etc.), institutions Environmental Assessment (EA) - An EA is a publication (schools, churches, etc.), health services (hospitals, clinics, that provides sufficient evidence and analyses to show etc.), and military buildings and installations. whether a proposed system will adversely affect the environment or be environmentally controversial. Compaction - The packing of soil together into a firmer, denser mass, generally caused by the pressure of great Erosion - The wearing away of the land surface by weight. detachment and movement of soil and rock fragments through the action of moving water and other geological agents. Contaminants - Any physical, chemical, biological, or radiological substances that have an adverse effect on air, Fauna - Animal life, especially the animal characteristics of a water, or soil. region, period, or special environment.

Council on Environmental Quality (CEQ) - An Executive Flora - Vegetation; plant life characteristic of a region, period, Office of the President composed of three members or special environment.

DRAFT ENVIRONMENTAL ASSESSMENT 97 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS GLOSSARY

Floodplain - The relatively flat area or lowlands adjoining a substantial hazard to human health or the environment. river, stream, ocean, lake, or other body of water that is Hazardous wastes are identified in 40 CFR 261.3 or susceptible to being inundated by floodwaters. applicable foreign law, rule, or regulation.

FONSI - Finding of No Significant Impact, a NEPA document. Hazardous Waste Storage - As defined in 40 CFR 260.10, ". . . the holding of hazardous waste for a temporary period, at Fugitive Dust - Particles light enough to be suspended in air, the end of which the hazardous waste is treated, disposed of, but not captured by a filtering system. For this document, this or stored elsewhere". refers to particles put in the air by moving vehicles and air movement over disturbed soils at construction sites. Hydric Soil - A soil that is saturated, flooded, or ponded long enough during the growing season to develop anaerobic Geology - Science which deals with the physical history of the (oxygen-lacking) conditions that favor the growth and earth, the rocks of which it is composed, and physical changes regeneration of hydrophytic vegetation. A wetland indicator. in the earth. Indirect Impact - An indirect impact is caused by a Proposed Groundwater - Water found below the ground surface. Action that occurs later in time or farther removed in distance, Groundwater may be geologic in origin and as pristine as it but is still reasonably foreseeable. Indirect impacts may was when it was entrapped by the surrounding rock or it may include induced changes in the pattern of land use, population be subject to daily or seasonal effects depending on the local density or growth rate, and related effects on air, water, and hydrologic cycle. Groundwater may be pumped from wells other natural and social systems. For example, referring to the and used for drinking water, irrigation, and other purposes. It possible direct impacts described above, the clearing of trees is recharged by precipitation or irrigation water soaking into for new development may have an indirect impact on area the ground. Thus, any contaminant in precipitation or irrigation wildlife by decreasing available habitat. water may be carried into groundwater. Industrial Land Use – Land uses of a relatively higher Hazardous Substance - Hazardous materials are defined intensity that are generally not compatible with residential within several laws and regulations to have certain meanings. development. Examples include light and heavy For this document, a hazardous material is any one of the manufacturing, mining, and chemical refining. following: Isolated Wetland – Areas that meet the wetland hydrology, Any substance designated pursuant to section 311 (b)(2)(A) vegetation, and hydric soil characteristics, but do not have a of the Clean Water Act. direct connection to the waters of the U.S. Any element, compound, mixture, solution, or substance Jurisdictional Wetland – Areas that meet the wetland designated pursuant to Section 102 of Comprehensive hydrology, vegetation, and hydric soil characteristics, and Environmental Response, Compensation and Liability Act have a direct connection to the waters of the U.S. These (CERCLA). wetlands are regulated by the USACE. Any hazardous substance as defined under the Resource Listed Species - Any plant or animal designated by a state or Conservation and Recovery Act (RCRA). the federal government as a threatened, endangered, special Any toxic pollutant listed under TSCA. concern, or candidate species.

Any hazardous air pollutant listed under Section 112 of CAA. Mitigation - Measures taken to reduce adverse impacts on the environment. Any imminently hazardous chemical substance or mixture with respect to which the EPA Administrator has taken action Mobile Sources - Vehicles, aircraft, watercraft, construction pursuant to Subsection 7 of TSCA. equipment, and other equipment that use internal combustion engines for energy sources. The term does not include: 1) Petroleum, including crude oil or any thereof, which is not otherwise specifically listed or Monitoring - A process of inspecting and recording the designated as a hazardous substance in a above. 2) Natural progress of mitigation measures implemented. gas, natural gas liquids, liquefied natural gas, or synthetic gas National Ambient Air Quality Standards (NAAQS) - usable for fuel (or mixtures of natural gas and such synthetic Nationwide standards set up by the USEPA for widespread gas). A list of hazardous substances is found in 40 CFR 302.4. air pollutants, as required by Section 109 of the Clean Air Act Hazardous Waste - A solid waste which, when improperly (CAA). Currently, six pollutants are regulated by primary and treated, stored, transported, or disposed of, poses a secondary NAAQS: carbon monoxide (CO), lead (Pb),

DRAFT ENVIRONMENTAL ASSESSMENT 98 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019 DEPARTMENT OF VETERANS AFFAIRS GLOSSARY

nitrogen dioxide (NO2), ozone (O3), particulate matter, and locale rather than in the world as a whole. Both short- and sulfur dioxide (SO2). long-term effects are relevant.

National Environmental Policy Act (NEPA) - U.S. statute Intensity. This refers to the severity of impact. Responsible that requires all federal agencies to consider the potential officials must bear in mind that more than one agency may effects of major federal actions on the human and natural make decisions about partial aspects of a major action. environment. Small quantity generator - A generator who generates Non-attainment Area - An area that has been designated by greater than 220 pounds but less than 2,200 pounds of the EPA or the appropriate state air quality agency as hazardous waste in a calendar month and who does not exceeding one or more national or state ambient air quality accumulate more than 13,200 pounds of hazardous waste at standards. any one time (if either threshold is exceeded, the generator becomes a large quantity generator). A small quantity Parcel - A plot of land, usually a division of a larger area. generator may accumulate hazardous waste up to 180 days Particulates or Particulate Matter - Fine liquid or solid from the accumulation start date. particles such as dust, smoke, mist, fumes, or smog found in Soil - The mixture of altered mineral and organic material at air. the earth's surface that supports plant life. Physiographic Region - A portion of the Earth's surface with Solid Waste - Any discarded material that is not excluded by a basically common topography and common morphology. section 261.4(a) or that is not excluded by variance granted Pollutant - A substance introduced into the environment that under sections 260.30 and 260.31. adversely affects the usefulness of a resource. Threatened species - Any species that is likely to become an Potable Water - Water which is suitable for drinking. endangered species within the foreseeable future throughout all or a significant portion of its range. Prime Agricultural land - A special category of highly productive cropland that is recognized and described by the Topography - The relief features or surface configuration of U.S. Department of Agriculture’s Natural Resources an area. Conservation Service and receives special protection under Toxic Substance - A harmful substance which includes the Surface Mining Law. elements, compounds, mixtures, and materials of complex Remediation - A long-term action that reduces or eliminates composition. a threat to the environment. Waters of the United States - Include the following: (1) All Riparian Areas - Areas adjacent to rivers and streams that waters which are currently being used, were used in the past, have a high density, diversity, and productivity of plant and or may be susceptible to use in interstate or foreign animal species relative to nearby uplands. commerce, including all waters which are subject to the ebb and flow of the tide. (2) All interstate waters including River Basin - The land area drained by a river and its interstate wetlands. (3) All other waters such as intrastate tributaries. lakes, rivers, streams (including intermittent streams), Sensitive Receptors - Include, but are not limited to, mudflats, sandflats, wetlands, sloughs, prairie potholes, wet asthmatics, children, and the elderly, as well as specific meadows, playa lakes, or natural ponds; the use, degradation facilities, such as long-term health care facilities, rehabilitation or destruction of which could affect interstate or foreign centers, convalescent centers, retirement homes, residences, commerce. schools, playgrounds, and childcare centers. Watershed - The region draining into a particular stream, Significant Impact - According to 40 CFR 1508.27, river, or entire river system. "significance" as used in NEPA requires consideration of both Wetlands - Areas that are regularly saturated by surface or context and intensity. groundwater and, thus, are characterized by a prevalence of Context. The significance of an action must be analyzed in vegetation that is adapted for life in saturated soil conditions. several contexts such as society as a whole (human, Examples include swamps, bogs, fens, marshes, and national), the affected region, the affected interests, and the estuaries. locality. Significance varies with the setting of the Proposed Wildlife Habitat - Set of living communities in which a wildlife Action. For instance, in the case of a site-specific action, population lives. significance would usually depend upon the effects in the

DRAFT ENVIRONMENTAL ASSESSMENT 99 PROPOSED VA OUTPATIENT CLINIC LARIMER COUNTY, COLORADO JULY 2019