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HomeMy WebLinkAboutPart-58-CEST-Format_2018_0627.pdf U.S. Department of Housing and Urban Development 451 Seventh Street, SW Washington, DC 20410 www.hud.gov espanol.hud.gov Environmental Review for Activity/Project that is Categorically Excluded Subject to Section 58.5 Pursuant to 24 CFR 58.35(a) Project Information Project Name: Renton Rental Assistance Demonstration (RAD) Rehabilitation Activities at Hillcrest Terrace, Evergreen Terrace, and Cole Manor. Responsible Entity: City of Renton Grant Recipient (if different than Responsible Entity): Renton Housing Authority State/Local Identifier: WA011 Preparer: Lisa Grueter, Principal, BERK Consulting, Inc. Certifying Officer Name and Title: Mayor Denis Law and designee, Greg Zimmerman, chair of the Environmental Review Committee Grant Recipient (if different than Responsible Entity): Renton Housing Authority via Renton Crest LLLP Consultant (if applicable): BERK Consulting, Inc. Direct Comments to: Matt Herrera, AICP Senior Planner Community & Economic Development Department City of Renton 1055 South Grady Way Renton, WA 98057 MHerrera@Rentonwa.gov 425.430.6593 Project Location: See Exhibit 1 for physical locations. Sites are listed below:  Hillcrest Terrace 1442 Hillcrest Lane NE  Evergreen Terrace 3027 NE 15th  Cole Manor 2811 NE 4TH Exhibit 1. Renton Housing Authority Properties and Hillcrest Terrace, Evergreen Terrace, and Cole Manor Under Evaluation Source: King County, City of Renton, BERK Consulting 2016 Description of the Proposed Project [24 CFR 50.12 & 58.32; 40 CFR 1508.25]: The Renton Housing Authority (RHA) proposes maintenance and rehabilitation activities, including:  Additional site lighting  General landscaping allowance to add marketability  No ground disturbance (i.e. less than one cubic foot of disturbed soil)  Addition of monument sign  Seal and stripe asphalt  Asphalt repair and concrete repair/grading for ADA accessibility  Window replacement (if necessary),  Masonry repair and sealing (if necessary),  Roof replacement (if necessary),  Storefront entry replacement (if necessary)  Community room upgrade (flooring, lighting, painting, etc.),  Boiler replacement (if necessary and applicable),  Exterior entryway and vestibule enhancements, and  Selective replacement of: lighting, flooring, painting, appliances, cabinets, countertops, base trim, baseboard heaters, shower surround, tub, medicine cabinet. See Attachment A for a more detailed description of proposed maintenance and rehabilitation activities. Level of Environmental Review Determination: The level of environmental review consists of a categorical exclusion since rehabilitation of buildings and improvements would fit under 24 CFR 58.35 (a)(3)(ii). (3) Rehabilitation of buildings and improvements when the following conditions are met: (ii) In the case of multifamily residential buildings: (A) Unit density is not changed more than 20 percent; (B) The project does not involve changes in land use from residential to non- residential; and (C) The estimated cost of rehabilitation is less than 75 percent of the total estimated cost of replacement after rehabilitation. Other activities are considered categorically excluded, not subject to Section 58.5: Affordable housing pre-development costs, including legal consulting, developer and other costs related to obtaining site options, project financing, administrative costs and fees for loan commitments, zoning approvals, and other related activities which do not have a physical impact, are listed as a categorical exclusion not subject to §58.5 (see 24 CFR §58.35(b)(6)). Following a review of federal laws and authorities through HUD worksheets included in Attachment B, the categorically excluded activities/projects convert to Exempt, per 58.34(a)(12) because there are no circumstances which require compliance with any of the federal laws and authorities cited at §58.5. Funding Information RAD provides a transfer of subsidy type. Transaction/construction is financed through tax credit equity and tax-exempt debt. This is considered a non-FHA transaction converting to Project- Based Vouchers (PBV) and subject to Part 58 review. Please also see Attachment A Project Description. Grant Number HUD Program Funding Amount NA Section 8 Project Based Vouchers $980,000, approximately Estimated Total HUD Funded Amount: See above. Estimated Total Project Cost (HUD and non-HUD funds) [24 CFR 58.32(d)]: See above. Compliance with 24 CFR 50.4, 58.5, and 58.6 Laws and Authorities Record below the compliance or conformance determinations for each statute, executive order, or regulation. Provide credible, traceable, and supportive source documentation for each authority. Where applicable, complete the necessary reviews or consultations and obtain or note applicable permits of approvals. Clearly note citations, dates/names/titles of contacts, and page references. Attach additional documentation as appropriate. Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR §58.5 and §58.6 Are formal compliance steps or mitigation required? Compliance determinations STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR 50.4 & 58.6 Airport Hazards 24 CFR Part 51 Subpart D Yes No None of the sites are within 2,500 feet of a civil airport or 15,000 feet of a military airport. Coastal Barrier Resources Coastal Barrier Resources Act, as amended by the Coastal Barrier Improvement Act of 1990 [16 USC 3501] Yes No Washington is not a state within units of the Coastal Barrier Resources System (CBRS). Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR §58.5 and §58.6 Are formal compliance steps or mitigation required? Compliance determinations Flood Insurance Flood Disaster Protection Act of 1973 and National Flood Insurance Reform Act of 1994 [42 USC 4001-4128 and 42 USC 5154a] Yes No None of the sites are within a mapped floodplain, nor are there abutting waterbodies. STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR 50.4 & 58.5 Clean Air Clean Air Act, as amended, particularly section 176(c) & (d); 40 CFR Parts 6, 51, 93 Yes No Not applicable. No new construction or conversion of uses are planned; the activities consist of maintenance and rehabilitation of existing buildings. Coastal Zone Management Coastal Zone Management Act, sections 307(c) & (d) Yes No Not applicable. The level of rehabilitation does not exceed the categorical exclusion threshold at 24 CFR Part 58.35(a). Contamination and Toxic Substances 24 CFR Part 50.3(i) & 58.5(i)(2) Yes No There is no evidence of known or suspected contamination at any of the three properties. No recognized environmental conditions were identified for any of the three sites. State laws are in place to address the potential for off-site environmental concerns near Cole Manor. The proponent has ordered lead testing on all buildings, and the HUD Regulation on Controlling Lead-Based Paint Hazards, 24 CFR Part 35, will be followed accordingly. Endangered Species Endangered Species Act of 1973, particularly section 7; 50 CFR Part 402 Yes No The sites were reviewed through the USFWS Information for Planning and Consultation (IPaC) Site and none were found to have critical habitats. Potential species that could be affected by development in the area based on the USFWS IPaC list of mammals, birds, and fish include: North American Wolverine, Marbled Murrelet, Streaked Horned Lark, Yellow-billed Cuckoo, and Bull Trout. However, the proposed maintenance and rehabilitation activities are anticipated to have no effect because:  Sites are previously disturbed developed sites, Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR §58.5 and §58.6 Are formal compliance steps or mitigation required? Compliance determinations  No change in impervious area is proposed,  No ground disturbance (defined as one cubic foot of disturbed soil) is proposed,  Landscaping improvements would not remove trees or shrubs,  Sites do not contain critical habitats and are not located in proximity to streams or wetlands, and  Re-roofing would not include galvanized material unless it has been sealed or otherwise confined so that it will not leach into stormwater. Explosive and Flammable Hazards 24 CFR Part 51 Subpart C Yes No The project does not include a hazardous facility and does not involve rehabilitation that would increase residential densities or conversions to other uses. Farmlands Protection Farmland Protection Policy Act of 1981, particularly sections 1504(b) and 1541; 7 CFR Part 658 Yes No Sites are in Renton’s city limits in a designated urban growth area under Washington’s Growth Management Act. The sites are fully developed. There are no agricultural uses onsite. Floodplain Management Executive Order 11988, particularly section 2(a); 24 CFR Part 55 Yes No None of the sites are within a mapped floodplain. The City is in good standing with the Flood Insurance Rate program. Historic Preservation National Historic Preservation Act of 1966, particularly sections 106 and 110; 36 CFR Part 800 Yes No No ground disturbance of the site is proposed per the project description. All sites have been reviewed for archaeological resources in 2016, and Hillcrest in 2010, and no cultural resources were discovered. Cole Manor is less than 45 years old. Hillcrest Terrace was evaluated in 2010 and found to be not eligible for the National Register of Historic Places in a Letter from DAHP dated December 9, 2010. A 2016 reconnaissance evaluation of the Evergreen Terrace Housing Complex did not identify any evidence that the property meets Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR §58.5 and §58.6 Are formal compliance steps or mitigation required? Compliance determinations criteria for historical significance. DAHP provided a determination that the property is not eligible for the NRHP on August 4, 2016. Per the 2016 Report, because Hillcrest and Evergreen Terrace have been determined not eligible for the NRHP, any alterations would not constitute an effect to historic properties (36 CFR 800.4 (2)(d)(1)). See Attachment C. Noise Abatement and Control Noise Control Act of 1972, as amended by the Quiet Communities Act of 1978; 24 CFR Part 51 Subpart B Yes No See Project Description. RHA will employ window replacements consisting of double glazed windows and improved doors at entries, where applicable. Sole Source Aquifers Safe Drinking Water Act of 1974, as amended, particularly section 1424(e); 40 CFR Part 149 Yes No The project consists of rehabilitation of multifamily buildings that does not increase size or capacity, and meets all applicable local groundwater regulations. Wetlands Protection Executive Order 11990, particularly sections 2 and 5 Yes No All three sites are developed in an urban environment. No wetlands are found on the three sites as documented in City critical area mapping. No new construction is proposed. Wild and Scenic Rivers Wild and Scenic Rivers Act of 1968, particularly section 7(b) and (c) Yes No There are no rivers in proximity to the three sites. ENVIRONMENTAL JUSTICE Environmental Justice Executive Order 12898 Yes No The residential sites are designated for low- income and senior households, and will continue to be used as such. The units will be maintained and rehabilitated to provide quality living environments. No adverse environmental impacts have been identified. Field Inspection (Date and completed by): Sites were reviewed in the field in 2016 as part of a cultural resources review per Attachment C. No additional field inspection has been conducted. Summary of Findings and Conclusions: The residential units will be maintained and rehabilitated to provide quality living environments. Sites are located in an urban environment and are already developed. No additional units or density are proposed, and no change of use is proposed. Proposed maintenance and rehabilitation activities would minimize effects on the environment by limiting ground disturbance and modernizing sites and units. No mitigation or consultation is required. Mitigation Measures and Conditions [40 CFR 1505.2(c)] Summarize below all mitigation measures adopted by the Responsible Entity to reduce, avoid, or eliminate adverse environmental impacts and to avoid non-compliance or non-conformance with the above-listed authorities and factors. These measures/conditions must be incorporated into project contracts, development agreements, and other relevant documents. The staff responsible for implementing and monitoring mitigation measures should be clearly identified in the mitigation plan. Law, Authority, or Factor Mitigation Measure NONE Determination: This categorically excluded activity/project converts to Exempt, per 58.34(a)(12) because there are no circumstances which require compliance with any of the federal laws and authorities cited at §58.5. Funds may be committed and drawn down after certification of this part for this (now) EXEMPT project; OR This categorically excluded activity/project cannot convert to Exempt because there are circumstances which require compliance with one or more federal laws and authorities cited at §58.5. Complete consultation/mitigation protocol requirements, publish NOI/RROF and obtain “Authority to Use Grant Funds” (HUD 7015.16) per Section 58.70 and 58.71 before committing or drawing down any funds; OR This project is now subject to a full Environmental Assessment according to Part 58 Subpart E due to extraordinary circumstances (Section 58.35(c)). Preparer Signature: __________________________________________Date:_6/27/18___ Name/Title/Organization: ______Lisa Grueter, AICP, Principal, BERK Consulting, Inc. ________________________________________________________________________ City of Renton Environmental Review Committee (ERC) Date: Signature: Chair Signature: Signature: Signature: This original, signed document and related supporting material must be retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (ref: 24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program(s).