HomeMy WebLinkAboutD_Part-58-CEST-Format_2018_0627_180709.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)).
PreparerSignature:t4cDate:6/27/18Name/Title/Organization:LisaGrueter,AICP,Principal,BERKConsulting,Inc.CityofRentonEnvironmentalReviewCommittee(ERC)Date:7/1Signature:9477%M7ft/26)Signature:s’t3714/12iy‘efQSignature:Signature:__________________________________Thisoriginal,signeddocumentandrelatedsupportingmaterialmustberetainedonfilebytheResponsibleEntityinanEnvironmentalReviewRecord(ERR)fortheactivity/project(ref:24CFRPart58.38)andinaccordancewithrecordkeepingrequirementsfortheHUDprogram(s).Gregg Zimmerman, AdministratorPublic Works DepartmentKelly Beymer, AdministratorCommunity Services DepartmentC.E. Vincent, AdministratorDepartment of Community & Economic DevelopmentRick M. Marshall, AdministratorRenton Regional Fire Authority