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Prospect Place Environmental AssessmentU.S. Department of Housing and Urban Development 451 Seventh Street, SW Washington, DC 20410 www.hud.gov espanol.hud.gov Environmental Assessment Determinations and Compliance Findings for HUD-assisted Projects 24 CFR Part 58 Project Information Project Name: Prospect-Place HEROS Number: 900000010239780 Responsible Entity (RE): NORTHAMPTON, 210 Main St Northampton MA, 01060 RE Preparer: Nathan Chung State / Local Identifier: Certifying Officer: Wayne Feiden, FAICP Grant Recipient (if different than Responsible Ent ity): Consultant (if applicabl e): Project Location: Planning and Sustainability, Northampton, MA 01060 Additional Location Information: N/A Direct Comments to: NChung@NorthamptonMA.gov Point of Contact: Point of Contact: Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 2 of 38 Statement of Purpose and Need for the Proposal [40 CFR 1508.9(b)]: This project will: Rehabilitate a vacant and uninhabitable property that is presently a neighborhood nuisance Create much needed new affordable rental housing for low- and moderate- income households Existing Conditions and Trends [24 CFR 58.40(a)]: This project will address significant capital needs in the building as identified in a Capital Needs Assessment. It will abate significant quantities of hazardous materials (primarily asbestos). The project complements efforts by the City and the State to locate affordable housing in ''areas of opportunity'' and in locations close to transit (bus stop and bike trail), close to schools, shopping, and other amenities. Maps, photographs, and other documentation of project location and description: Determination:  Finding of No Significant Impact [24 CFR 58.40(g)(1); 40 CFR 1508.13] The project will not result in a significant impact on the quality of human environment Finding of Significant Impact Approval Documents: Prospect Place-HEROS signed EA.pdf 7015.15 certified by Certifying Officer on: 7015.16 certified by Authorizing Officer on: Description of the Proposed Project [24 CFR 50.12 & 58.32; 40 CFR 1508.25]: All project work will take place on a 6.2 acre previously developed lot that contains an approximately 72,000 sf two-story structure constructed in 1971. This building served previously as a nursing home, having 84 rooms and common areas, and has been vacant since 2011. During the vacancy period, the building suffered deterioration and vandalism. Scope of this Project includes: Stabilize and secure the structure; demolition of a front portico not original to the building (circa 2005); hazardous materials removal; gut rehabilitation of the building including: replace windows, reconfigure interior partitions, add insulation, install new mechanical systems and finishes; install PV solar panels; potentially add second story to small single-story portions of the existing building. Anticipated site work includes: repair and / or upgrade connections to public utilities (as needed); alter existing driveways to accommodate new traffic pattern; repair and / or add sidewalks; repair and / or reconfigure existing parking lots; revitalize landscaping; add new fencing; and other outdoor amenities. After rehabilitation, the property will contain an estimated 60 affordable rental units in a range of sizes (studios to 3-bedroom apartments) serving a range of household incomes from < 30% AMI to 100% AMI. The Project will include suitable common areas and interior and exterior amenities to serve tenants. Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 3 of 38 Funding Information Estimated Total HUD Funded, Assisted or Insured Amount: $750,000.00 Estimated Total Project Cost [24 CFR 58.2 (a) (5)]: $25,586,442.00 Compliance with 24 CFR §50.4, §58.5 and §58.6 Laws and Authorities Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR §50.4, §58.5, and §58.6 Are formal compliance steps or mitigation required? Compliance determination (See Appendix A for source determinations) STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR §50.4 & § 58.6 Airport Hazards Clear Zones and Accident Potential Zones; 24 CFR Part 51 Subpart D  Yes  No The project site is not within 15,000 feet of a military airport or 2,500 feet of a civilian airport. The project is in compliance with Airport Hazards requirements. No airport within close proximity. Northampton Airport is approximately 2 miles from project site. Only small, non-commercial planes use this airport. Noise from planes does not impact this site. Coastal Barrier Resources Act Coastal Barrier Resources Act, as amended by the Coastal Barrier  Yes  No This project is not located in a CBRS Unit. Therefore, this project has no potential to impact a CBRS Unit and is in Grant / Project Identification Number HUD Program Program Name CFDA #14.195 Public Housing Housing Choice Voucher Program CFDA #14.218 Community Planning and Development (CPD) Community Development Block Grants (CDBG) (Entitlement) CFDA #14.239 Community Planning and Development (CPD) HOME Program CFDA #14.275 Other HUD Housing Trust Fund Unlisted on SAM.gov Community Planning and Development (CPD) HOME-ARP Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 4 of 38 Improvement Act of 1990 [16 USC 3501] compliance with the Coastal Barrier Resources Act. 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 Based on the project description the project includes no activities that would require further evaluation under this section. The project does not require flood insurance or is excepted from flood insurance. While flood insurance may not be mandatory in this instance, HUD recommends that all insurable structures maintain flood insurance under the National Flood Insurance Program (NFIP). The project is in compliance with Flood Insurance requirements. According to FEMA Flood Map #2501670102A dated April 3, 1978, the subject lies in a Zone C and so is not within a 100 year or 500 year floodplain. See maps attached. STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR §50.4 & § 58.5 Air Quality Clean Air Act, as amended, particularly section 176(c) & (d); 40 CFR Parts 6, 51, 93  Yes  No The project's county or air quality management district is in attainment status for all criteria pollutants. The project is in compliance with the Clean Air Act. There is no heavy industrial uses and no known air contaminants in the immediate area. Coastal Zone Management Act Coastal Zone Management Act, sections 307(c) & (d)  Yes  No This project is not located in or does not affect a Coastal Zone as defined in the state Coastal Management Plan. The project is in compliance with the Coastal Zone Management Act. Contamination and Toxic Substances 24 CFR 50.3(i) & 58.5(i)(2)]  Yes  No Site contamination was evaluated as follows: ASTM Phase I ESA. On-site or nearby toxic, hazardous, or radioactive substances were found that could affect the health and safety of project occupants or conflict with the intended use of the property. The adverse environmental impacts can be mitigated. With mitigation, identified in the mitigation section of this review, the project will be in compliance with contamination and toxic substances requirements. Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 5 of 38 Endangered Species Act Endangered Species Act of 1973, particularly section 7; 50 CFR Part 402  Yes  No This project will have No Effect on listed species due to the nature of the activities involved in the project. This project is in compliance with the Endangered Species Act. Explosive and Flammable Hazards Above-Ground Tanks)[24 CFR Part 51 Subpart C  Yes  No There are no current or planned stationary aboveground storage containers of concern within 1 mile of the project site. The project is in compliance with explosive and flammable hazard requirements. EBI, the 2021 ESA firm previously submitted a Phase I ESA report on September 18th, 2015. The firm identified one 1,000- gallon AST (above-ground storage tank) located on the west side of the building during the past assessment. It indicated that the AST historically contained liquid propane in connection with an aboveground pool previously located adjacent to the building. The AST was reportedly empty. In the newer ESA report submitted on February 18th, 2021, the firm did not observe the AST due to extensive snow cover. On 2/10/2022, Valley CDC, the CDBG subrecipient, visually inspected the property and could no longer find the tank. On 2/11/2022, Nathan Chung, the CDBG administrator for the Responsible Entity, City of Northampton visually inspected the property, took photographs, and could no longer find the tank. Attached are three ZIP files of the photographs he took. Farmlands Protection Farmland Protection Policy Act of 1981, particularly sections 1504(b) and 1541; 7 CFR Part 658  Yes  No This project does not include any activities that could potentially convert agricultural land to a non-agricultural use. The project is in compliance with the Farmland Protection Policy Act. Floodplain Management Executive Order 11988, particularly section 2(a); 24 CFR Part 55  Yes  No This project does not occur in a floodplain. One low-lying depression on site has been identified as a potential vernal pool. This location will not be disturbed or impacted by the planned Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 6 of 38 redevelopment. The project is in compliance with Executive Order 11988. Historic Preservation National Historic Preservation Act of 1966, particularly sections 106 and 110; 36 CFR Part 800  Yes  No Based on the project description the project has No Potential to Cause Effects. The project is in compliance with Section 106. 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 Based on the project description, this project includes no activities that would require further evaluation under HUD's noise regulation. The project is in compliance with HUD's Noise regulation. It involves rehabilitating and converting a vacant nursing home into about 60 units of affordable housing. It will not generate excessive noise. Sole Source Aquifers Safe Drinking Water Act of 1974, as amended, particularly section 1424(e); 40 CFR Part 149  Yes  No Based on the project description, the project consists of activities that are unlikely to have an adverse impact on groundwater resources. The project is in compliance with Sole Source Aquifer requirements. Wetlands Protection Executive Order 11990, particularly sections 2 and 5  Yes  No Based on the project description this project includes no activities that would require further evaluation under this section. The project is in compliance with Executive Order 11990. Wild and Scenic Rivers Act Wild and Scenic Rivers Act of 1968, particularly section 7(b) and (c)  Yes  No This project is not within proximity of a NWSRS river. The project is in compliance with the Wild and Scenic Rivers Act. HUD HOUSING ENVIRONMENTAL STANDARDS ENVIRONMENTAL JUSTICE Environmental Justice Executive Order 12898  Yes  No No adverse environmental impacts were identified in the project's total environmental review. The project is in compliance with Executive Order 12898. This Project will benefit low- and moderate- income persons by providing safe, health, affordable housing in a desirable community and neighborhood. It will allow low-income community members to live in energy efficient housing using alternative energy sources. Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 7 of 38 Environmental Assessment Factors [24 CFR 58.40; Ref. 40 CFR 1508.8 &1508.27] Impact Codes: An impact code from the following list has been used to make the determination of impact for each factor. (1) Minor beneficial impact (2) No impact anticipated (3) Minor Adverse Impact – May require mitigation (4) Significant or potentially significant impact requiring avoidance or modification which may require an Environmental Impact Statement. Environmental Assessment Factor Impact Code Impact Evaluation Mitigation LAND DEVELOPMENT Conformance with Plans / Compatible Land Use and Zoning / Scale and Urban Design 2 This Project conforms to local zoning under a Special Permit. Its use (residential) is compatible with surrounding uses (also residential). It is located near single family and multi- family properties, including two townhouse condominiums. Soil Suitability / Slope/ Erosion / Drainage and Storm Water Runoff 2 This Project is located on a fully developed site with pre-existing connections to the City's storm-water system. Hazards and Nuisances including Site Safety and Site-Generated Noise 1 The proposed residential use will not create any hazards or nuisances. New traffic pattern is expected to decrease the current traffic safety hazard of driveway connected to Bridge Road. Energy Consumption/Energy Efficiency 1 Added insulation, energy efficient mechanical systems, and PV solar panels will reduce energy consumption at this property over its prior occupied use levels. SOCIOECONOMIC Employment and Income Patterns 1 This Project will create new jobs during construction and affordable housing in proximity to local jobs. Job growth will be created through increased levels of property management and maintenance staff and a part-time Resident Services Coordinator. Demographic Character Changes / Displacement 1 The Project will increase the economic diversity in Northampton by providing Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 8 of 38 Environmental Assessment Factor Impact Code Impact Evaluation Mitigation LAND DEVELOPMENT affordable units in a community in which lower income households are often priced out. COMMUNITY FACILITIES AND SERVICES Educational and Cultural Facilities (Access and Capacity) 2 This Project will not have direct impact on educational and cultural facilities. Commercial Facilities (Access and Proximity) 2 This Project will not impact commercial facilities. Although this project converts a commercial use (nursing home) to a residential use, the long-term vacancy of the property (11 years) means the commercial use was no longer viable. Health Care / Social Services (Access and Capacity) 1 Through a new Resident Services Coordinator position, low income tenants will be provided with case management services and will improve their utilization of community-based health and social services. Solid Waste Disposal and Recycling (Feasibility and Capacity) 2 Solid waste disposal and recycling will be managed through the use of on-site dumpsters and a contract with a reputable waste disposal company. During construction, GC will meet targets for recycling of demolition and construction waste. Waste Water and Sanitary Sewers (Feasibility and Capacity) 2 This Project will make use of the City (public) sewer system. It is expected to have lower use levels than the former nursing home use. Water Supply (Feasibility and Capacity) 2 This Project will use the City (public) water system. Low flow fixtures will conserve water use. Public Safety - Police, Fire and Emergency Medical 2 This Project does not anticipate any unusual burden on public safety services. Use of Emergency Medical is expected to be far less than in its former, nursing home use. Parks, Open Space and Recreation (Access and Capacity) 1 It is expected that some new outdoor amenities will be added--potential for gardens, play-ground, or other recreational uses. Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 9 of 38 Environmental Assessment Factor Impact Code Impact Evaluation Mitigation LAND DEVELOPMENT Transportation and Accessibility (Access and Capacity) 1 The Project is ideally located for residents to access public transportation, being on the PVTA bus line and directly adjacent to a bus stop. The site is walking distance to a major shopping center, park, YMCA, and public schools. Most locations are connected via existing sidewalks. It is located on a main road and within two miles of several junctions with I-91, the primary transportation corridor for the Pioneer Valley. It is only 1,000 feet from a well-used bike trail that is plowed during winter. Handicapped access at this property will be excellent, with entry on grade and vertical access via elevator. All areas will be visitable and there will be an anticipated 5 handicapped accessible apartments. NATURAL FEATURES Unique Natural Features /Water Resources 2 This is a developed, residential site. There are no unique natural features or water resources on this site. Vegetation / Wildlife (Introduction, Modification, Removal, Disruption, etc.) 2 This is a developed, residential site. Other Factors Supporting documentation Additional Studies Performed: 10/4/16 MEP Existing Conditions Report, ANSwer Engineers (Uploaded here) 2/13/17 Building Survey Report, Northampton Building Dept (Uploaded here) 2/18/21 Phase I Environmental Site Assessment, EBI Consulting (Uploaded on section 2005 - "Contamination and Toxic Substances - Multifamily and Nonresidential Properties") 2/18/21 Property Condition Report, EBI Consulting (Uploaded on section 2005 - "Contamination and Toxic Substances - Multifamily and Nonresidential Properties") 3/2021 Preliminary Asbestos Report, SWCA (Uploaded on section 2005 - "Contamination and Toxic Substances - Multifamily and Nonresidential Properties") 1/5/22 Hazardous Materials Inspection Report, ATLAS Technical Consultants LLC Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 10 of 38 (Uploaded on section 2005 - "Contamination and Toxic Substances - Multifamily and Nonresidential Properties" Supersedes the SWCA preliminary asbestos report) Northampton Bldg Dept Summary on 737 Bridge St 20170213.pdf MEP Existing Bldg Conditions Report 20161014.pdf Field Inspection [Optional]: Date and completed by: Wayne Feiden 2/10/2022 12:00:00 AM List of Sources, Agencies and Persons Consulted [40 CFR 1508.9(b)]: Northampton Building Department Northampton Fire Department Extensive list of consultations took place as part of the Phase I Environmental Site Assessment (see Report for full listing). Massachusetts Historical Commission Northampton Dept of Planning & Sustainability Mayor's Office & Dept of Housing / CDBG Northampton Housing Partnership Community Economic Development Assistance Corporation (CEDAC) Mass Housing Valley Community Development Real Estate Committee & Board of Directors List of Permits Obtained: Not applicable Public Outreach [24 CFR 58.43]: Northampton Housing Partnership - Presentation via zoom on January 10, 2022 - Invitation to meeting from public notice posting and outreach to neighbors Abutters / Neighbors - Direct mail to abutters on 1/24/22 - Meeting w/ abutters scheduled for 2/15/22 Cumulative Impact Analysis [24 CFR 58.32]: Not applicable. Alternatives [24 CFR 58.40(e); 40 CFR 1508.9] Not applicable. No Action Alternative [24 CFR 58.40(e)] Not applicable. Summary of Findings and Conclusions: Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 11 of 38 Based on the discussion above, this Project will not impose any adverse environmental conditions and will improve a number of existing conditions at this location. Mitigation Measures and Conditions [CFR 1505.2(c)]: Summarized below are 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 or Condition Comments on Completed Measures Mitigation Plan Complete Contamination and Toxic Substances Phase I ESA found potential asbestos-containing materials, potential lead-based paint, and noticeable mold combined with moisture infiltration. These conditions are outside the scope of ASTM E 1527-13 and are not considered recognized environmental conditions (REC). Hazardous Materials Assessment has been conducted and all identified hazardous materials (primarily asbestos) will be abated prior to renovation. The abatement will be a combination of engineering controls through removal and institutional controls through a Operation and Management Plan for lead and asbestos. The ESA Report, Property Condition Report, and Hazardous Materials Inspection Report are attached. N/A Hazardous Materials Assessment has been conducted and all identified hazardous materials (primarily asbestos) will be abated prior to renovation. Project Mitigation Plan Valley CDC, the CDBG subrecipient who is carrying out the Prospect Place project, will perform abatement as part of its construction and rehabilitation process according to proper procedures. Attached are the abatement plans for lead, asbestos, and other hazardous materials. 183BW21076 SPEC SECTION 020820 MiscHazmatRemoval.pdf Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 12 of 38 183BW21076 SPEC SECTION 020810 DisturbanceofLeadCadmiumChromium.pdf 183BW21076 SPEC Asbestos and PCB Abatement.pdf Supporting documentation on completed measures Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 13 of 38 APPENDIX A: Related Federal Laws and Authorities Airport Hazards General policy Legislation Regulation It is HUD’s policy to apply standards to prevent incompatible development around civil airports and military airfields. 24 CFR Part 51 Subpart D 1. To ensure compatible land use development, you must determine your site’s proximity to civil and military airports. Is your project within 15,000 feet of a military airport or 2,500 feet of a civilian airport?  No Based on the response, the review is in compliance with this section. Document and upload the map showing that the site is not within the applicable distances to a military or civilian airport below Yes Screen Summary Compliance Determination The project site is not within 15,000 feet of a military airport or 2,500 feet of a civilian airport. The project is in compliance with Airport Hazards requirements. No airport within close proximity. Northampton Airport is approximately 2 miles from project site. Only small, non-commercial planes use this airport. Noise from planes does not impact this site. Supporting documentation Overview and Detail Maps.pdf Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 14 of 38 Coastal Barrier Resources General requirements Legislation Regulation HUD financial assistance may not be used for most activities in units of the Coastal Barrier Resources System (CBRS). See 16 USC 3504 for limitations on federal expenditures affecting the CBRS. Coastal Barrier Resources Act (CBRA) of 1982, as amended by the Coastal Barrier Improvement Act of 1990 (16 USC 3501) 1. Is the project located in a CBRS Unit?  No Document and upload map and documentation below. Yes Compliance Determination This project is not located in a CBRS Unit. Therefore, this project has no potential to impact a CBRS Unit and is in compliance with the Coastal Barrier Resources Act. Supporting documentation Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 15 of 38 Flood Insurance General requirements Legislation Regulation Certain types of federal financial assistance may not be used in floodplains unless the community participates in National Flood Insurance Program and flood insurance is both obtained and maintained. Flood Disaster Protection Act of 1973 as amended (42 USC 4001-4128) 24 CFR 50.4(b)(1) and 24 CFR 58.6(a) and (b); 24 CFR 55.1(b). 1. Does this project involve financial assistance for construction, rehabilitation, or acquisition of a mobile home, building, or insurable personal property?  No. This project does not require flood insurance or is excepted from flood insurance. Based on the response, the review is in compliance with this section. Yes 4. While flood insurance is not mandatory for this project, HUD strongly recommends that all insurable structures maintain flood insurance under the National Flood Insurance Program (NFIP). Will flood insurance be required as a mitigation measure or condition? Yes  No Screen Summary Compliance Determination Based on the project description the project includes no activities that would require further evaluation under this section. The project does not require flood insurance or is excepted from flood insurance. While flood insurance may not be mandatory in this instance, HUD recommends that all insurable structures maintain flood insurance under the National Flood Insurance Program (NFIP). The project is in compliance with Flood Insurance requirements. According to FEMA Flood Map #2501670102A dated April 3, 1978, the subject lies in a Zone C and so is not within a 100 year or 500 year floodplain. See maps attached. Supporting documentation FEMA map.pdf Are formal compliance steps or mitigation required? Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 16 of 38 Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 17 of 38 Air Quality General requirements Legislation Regulation The Clean Air Act is administered by the U.S. Environmental Protection Agency (EPA), which sets national standards on ambient pollutants. In addition, the Clean Air Act is administered by States, which must develop State Implementation Plans (SIPs) to regulate their state air quality. Projects funded by HUD must demonstrate that they conform to the appropriate SIP. Clean Air Act (42 USC 7401 et seq.) as amended particularly Section 176(c) and (d) (42 USC 7506(c) and (d)) 40 CFR Parts 6, 51 and 93 1. Does your project include new construction or conversion of land use facilitating the development of public, commercial, or industrial facilities OR five or more dwelling units?  Yes No Air Quality Attainment Status of Project’s County or Air Quality Management District 2. Is your project’s air quality management district or county in non-attainment or maintenance status for any criteria pollutants?  No, project’s county or air quality management district is in attainment status for all criteria pollutants. Yes, project’s management district or county is in non-attainment or maintenance status for the following criteria pollutants (check all that apply): Screen Summary Compliance Determination The project's county or air quality management district is in attainment status for all criteria pollutants. The project is in compliance with the Clean Air Act. There is no heavy industrial uses and no known air contaminants in the immediate area. Supporting documentation Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 18 of 38 Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 19 of 38 Coastal Zone Management Act General requirements Legislation Regulation Federal assistance to applicant agencies for activities affecting any coastal use or resource is granted only when such activities are consistent with federally approved State Coastal Zone Management Act Plans. Coastal Zone Management Act (16 USC 1451-1464), particularly section 307(c) and (d) (16 USC 1456(c) and (d)) 15 CFR Part 930 1. Is the project located in, or does it affect, a Coastal Zone as defined in your state Coastal Management Plan? Yes  No Based on the response, the review is in compliance with this section. Document and upload all documents used to make your determination below. Screen Summary Compliance Determination This project is not located in or does not affect a Coastal Zone as defined in the state Coastal Management Plan. The project is in compliance with the Coastal Zone Management Act. Supporting documentation Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 20 of 38 Contamination and Toxic Substances General requirements Legislation Regulations It is HUD policy that all properties that are being proposed for use in HUD programs be free of hazardous materials, contamination, toxic chemicals and gases, and radioactive substances, where a hazard could affect the health and safety of the occupants or conflict with the intended utilization of the property. 24 CFR 58.5(i)(2) 24 CFR 50.3(i) 1. How was site contamination evaluated? Select all that apply. Document and upload documentation and reports and evaluation explanation of site contamination below.  American Society for Testing and Materials (ASTM) Phase I Environmental Site Assessment (ESA) ASTM Phase II ESA Remediation or clean-up plan ASTM Vapor Encroachment Screening None of the Above 2. Were any on-site or nearby toxic, hazardous, or radioactive substances found that could affect the health and safety of project occupants or conflict with the intended use of the property? (Were any recognized environmental conditions or RECs identified in a Phase I ESA and confirmed in a Phase II ESA?) No  Yes 3. Mitigation Document and upload the mitigation needed according to the requirements of the appropriate federal, state, tribal, or local oversight agency. If the adverse environmental effects cannot be mitigated, then HUD assistance may not be used for the project at this site. Can adverse environmental impacts be mitigated? Adverse environmental impacts cannot feasibly be mitigated. Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 21 of 38 4. Describe how compliance was achieved in the text box below. Include any of the following that apply: State Voluntary Clean-up Program, a No Further Action letter, use of engineering controls, or use of institutional controls. Phase I ESA found potential asbestos-containing materials, potential lead-based paint, and noticeable mold combined with moisture infiltration. These conditions are outside the scope of ASTM E 1527-13 and are not considered recognized environmental conditions (REC). Hazardous Materials Assessment has been conducted and all identified hazardous materials (primarily asbestos) will be abated prior to renovation. The abatement will be a combination of engineering controls through removal and institutional controls through a Operation and Management Plan for lead and asbestos. The ESA Report, Property Condition Report, and Hazardous Materials Inspection Report are attached. If a remediation plan or clean-up program was necessary, which standard does it follow? Screen Summary Compliance Determination Site contamination was evaluated as follows: ASTM Phase I ESA. On-site or nearby toxic, hazardous, or radioactive substances were found that could affect the health and safety of project occupants or conflict with the intended use of the property. The adverse environmental impacts can be mitigated. With mitigation, identified in the mitigation section of this review, the project will be in compliance with contamination and toxic substances requirements. Supporting documentation Prospect Place 737 Bridge Rd Northampton Prelim Asb Assessment Report FINAL 032321.pdf HazMat Inspection Report Dec 2021(1).pdf  Yes, adverse environmental impacts can be eliminated through mitigation. Document and upload all mitigation requirements below. Complete removal  Risk-based corrective action (RBCA) Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 22 of 38 EBI Property Condition Assessment 20210218.pdf EBI Phase I ESA 20210218.pdf Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 23 of 38 Endangered Species General requirements ESA Legislation Regulations Section 7 of the Endangered Species Act (ESA) mandates that federal agencies ensure that actions that they authorize, fund, or carry out shall not jeopardize the continued existence of federally listed plants and animals or result in the adverse modification or destruction of designated critical habitat. Where their actions may affect resources protected by the ESA, agencies must consult with the Fish and Wildlife Service and/or the National Marine Fisheries Service (“FWS” and “NMFS” or “the Services”). The Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.); particularly section 7 (16 USC 1536). 50 CFR Part 402 1. Does the project involve any activities that have the potential to affect specifies or habitats?  No, the project will have No Effect due to the nature of the activities involved in the project. This selection is only appropriate if none of the activities involved in the project have potential to affect species or habitats. Examples of actions without potential to affect listed species may include: purchasing existing buildings, completing interior renovations to existing buildings, and replacing exterior paint or siding on existing buildings. Based on the response, the review is in compliance with this section. No, the project will have No Effect based on a letter of understanding, memorandum of agreement, programmatic agreement, or checklist provided by local HUD office Yes, the activities involved in the project have the potential to affect species and/or habitats. Screen Summary Compliance Determination This project will have No Effect on listed species due to the nature of the activities involved in the project. This project is in compliance with the Endangered Species Act. Supporting documentation Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 24 of 38 MA Estimated Habitats on 737 Bridge Rd.pdf Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 25 of 38 Explosive and Flammable Hazards General requirements Legislation Regulation HUD-assisted projects must meet Acceptable Separation Distance (ASD) requirements to protect them from explosive and flammable hazards. N/A 24 CFR Part 51 Subpart C 1. Is the proposed HUD-assisted project itself the development of a hazardous facility (a facility that mainly stores, handles or processes flammable or combustible chemicals such as bulk fuel storage facilities and refineries)?  No Yes 2. Does this project include any of the following activities: development, construction, rehabilitation that will increase residential densities, or conversion? No  Yes 3. Within 1 mile of the project site, are there any current or planned stationary aboveground storage containers that are covered by 24 CFR 51C? Containers that are NOT covered under the regulation include: • Containers 100 gallons or less in capacity, containing common liquid industrial fuels OR • Containers of liquified petroleum gas (LPG) or propane with a water volume capacity of 1,000 gallons or less that meet the requirements of the 2017 or later version of National Fire Protection Association (NFPA) Code 58. If all containers within the search area fit the above criteria, answer “No.” For any other type of aboveground storage container within the search area that holds one of the flammable or explosive materials listed in Appendix I of 24 CFR part 51 subpart C, answer “Yes.”  No Based on the response, the review is in compliance with this section. Document and upload all documents used to make your determination below. Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 26 of 38 Yes Screen Summary Compliance Determination There are no current or planned stationary aboveground storage containers of concern within 1 mile of the project site. The project is in compliance with explosive and flammable hazard requirements. EBI, the 2021 ESA firm previously submitted a Phase I ESA report on September 18th, 2015. The firm identified one 1,000-gallon AST (above-ground storage tank) located on the west side of the building during the past assessment. It indicated that the AST historically contained liquid propane in connection with an aboveground pool previously located adjacent to the building. The AST was reportedly empty. In the newer ESA report submitted on February 18th, 2021, the firm did not observe the AST due to extensive snow cover. On 2/10/2022, Valley CDC, the CDBG subrecipient, visually inspected the property and could no longer find the tank. On 2/11/2022, Nathan Chung, the CDBG administrator for the Responsible Entity, City of Northampton visually inspected the property, took photographs, and could no longer find the tank. Attached are three ZIP files of the photographs he took. Supporting documentation 737 Bridge Rd Ext Photos 20220211 3 of 3.zip 737 Bridge Rd Ext Photos 20220211 2 of 3.zip 737 Bridge Rd Ext Photos 20220211 1 of 3.zip Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 27 of 38 Farmlands Protection General requirements Legislation Regulation The Farmland Protection Policy Act (FPPA) discourages federal activities that would convert farmland to nonagricultural purposes. Farmland Protection Policy Act of 1981 (7 U.S.C. 4201 et seq.) 7 CFR Part 658 1. Does your project include any activities, including new construction, acquisition of undeveloped land or conversion, that could convert agricultural land to a non-agricultural use? Yes  No If your project includes new construction, acquisition of undeveloped land or conversion, explain how you determined that agricultural land would not be converted: Based on the response, the review is in compliance with this section. Document and upload all documents used to make your determination below. Screen Summary Compliance Determination This project does not include any activities that could potentially convert agricultural land to a non-agricultural use. The project is in compliance with the Farmland Protection Policy Act. Supporting documentation Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 28 of 38 Floodplain Management General Requirements Legislation Regulation Executive Order 11988, Floodplain Management, requires federal activities to avoid impacts to floodplains and to avoid direct and indirect support of floodplain development to the extent practicable. Executive Order 11988 24 CFR 55 1. Do any of the following exemptions apply? Select the applicable citation? [only one selection possible] 55.12(c)(3) 55.12(c)(4) 55.12(c)(5) 55.12(c)(6) 55.12(c)(7) 55.12(c)(8) 55.12(c)(9) 55.12(c)(10) 55.12(c)(11)  None of the above 2. Upload a FEMA/FIRM map showing the site here: FEMA map(1).pdf The Federal Emergency Management Agency (FEMA) designates floodplains. The FEMA Map Service Center provides this information in the form of FEMA Flood Insurance Rate Maps (FIRMs). For projects in areas not mapped by FEMA, use the best available information to determine floodplain information. Include documentation, including a discussion of why this is the best available information for the site. Does your project occur in a floodplain? Based on the response, the review is in compliance with this section. Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 29 of 38 Screen Summary Compliance Determination This project does not occur in a floodplain. One low-lying depression on site has been identified as a potential vernal pool. This location will not be disturbed or impacted by the planned redevelopment. The project is in compliance with Executive Order 11988. Supporting documentation Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 30 of 38 Historic Preservation General requirements Legislation Regulation Regulations under Section 106 of the National Historic Preservation Act (NHPA) require a consultative process to identify historic properties, assess project impacts on them, and avoid, minimize, or mitigate adverse effects Section 106 of the National Historic Preservation Act (16 U.S.C. 470f) 36 CFR 800 “Protection of Historic Properties” https://www.govinfo.gov/content/pkg/CF R-2012-title36-vol3/pdf/CFR-2012-title36- vol3-part800.pdf Threshold Is Section 106 review required for your project? No, because the project consists solely of activities listed as exempt in a Programmatic Agreement (PA ). (See the PA Database to find applicable PAs.)  No, because the project consists solely of activities included in a No Potential to Cause Effects memo or other determination [36 CFR 800.3(a)(1)]. Yes, because the project includes activities with potential to cause effects (direct or indirect). Threshold (b). Document and upload the memo or explanation/justification of the other determination below: Based on the response, the review is in compliance with this section. Screen Summary Compliance Determination Based on the project description the project has No Potential to Cause Effects. The project is in compliance with Section 106. Massachusetts Historical Commission cleared the project on January 26th, 2022. Documents are attached. From the clearance letter: "After review of MHC files and the materials you submitted, it has been determined that the project is unlikely to affect significant historic or archaeological resources." Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 31 of 38 Supporting documentation MHC PNF for 737 Bridge Rd Northampton.pdf MHC Clearance Letter 20220126.pdf Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 32 of 38 Noise Abatement and Control General requirements Legislation Regulation HUD’s noise regulations protect residential properties from excessive noise exposure. HUD encourages mitigation as appropriate. Noise Control Act of 1972 General Services Administration Federal Management Circular 75-2: “Compatible Land Uses at Federal Airfields” Title 24 CFR 51 Subpart B 1. What activities does your project involve? Check all that apply: New construction for residential use Rehabilitation of an existing residential property A research demonstration project which does not result in new construction or reconstruction An interstate land sales registration Any timely emergency assistance under disaster assistance provision or appropriations which are provided to save lives, protect property, protect public health and safety, remove debris and wreckage, or assistance that has the effect of restoring facilities substantially as they existed prior to the disaster  None of the above Screen Summary Compliance Determination Based on the project description, this project includes no activities that would require further evaluation under HUD's noise regulation. The project is in compliance with HUD's Noise regulation. It involves rehabilitating and converting a vacant nursing home into about 60 units of affordable housing. It will not generate excessive noise. Supporting documentation Are formal compliance steps or mitigation required? Yes Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 33 of 38  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 34 of 38 Sole Source Aquifers General requirements Legislation Regulation The Safe Drinking Water Act of 1974 protects drinking water systems which are the sole or principal drinking water source for an area and which, if contaminated, would create a significant hazard to public health. Safe Drinking Water Act of 1974 (42 U.S.C. 201, 300f et seq., and 21 U.S.C. 349) 40 CFR Part 149 1. Does the project consist solely of acquisition, leasing, or rehabilitation of an existing building(s)?  Yes Based on the response, the review is in compliance with this section. No Screen Summary Compliance Determination Based on the project description, the project consists of activities that are unlikely to have an adverse impact on groundwater resources. The project is in compliance with Sole Source Aquifer requirements. Supporting documentation Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 35 of 38 Wetlands Protection General requirements Legislation Regulation Executive Order 11990 discourages direct or indirect support of new construction impacting wetlands wherever there is a practicable alternative. The Fish and Wildlife Service’s National Wetlands Inventory can be used as a primary screening tool, but observed or known wetlands not indicated on NWI maps must also be processed Off-site impacts that result in draining, impounding, or destroying wetlands must also be processed. Executive Order 11990 24 CFR 55.20 can be used for general guidance regarding the 8 Step Process. 1. Does this project involve new construction as defined in Executive Order 11990, expansion of a building’s footprint, or ground disturbance? The term "new construction" shall include draining, dredging, channelizing, filling, diking, impounding, and related activities and any structures or facilities begun or authorized after the effective date of the Order  No Based on the response, the review is in compliance with this section. Yes Screen Summary Compliance Determination Based on the project description this project includes no activities that would require further evaluation under this section. The project is in compliance with Executive Order 11990. Supporting documentation Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 36 of 38 Wild and Scenic Rivers Act General requirements Legislation Regulation The Wild and Scenic Rivers Act provides federal protection for certain free-flowing, wild, scenic and recreational rivers designated as components or potential components of the National Wild and Scenic Rivers System (NWSRS) from the effects of construction or development. The Wild and Scenic Rivers Act (16 U.S.C. 1271-1287), particularly section 7(b) and (c) (16 U.S.C. 1278(b) and (c)) 36 CFR Part 297 1. Is your project within proximity of a NWSRS river?  No Yes, the project is in proximity of a Designated Wild and Scenic River or Study Wild and Scenic River. Yes, the project is in proximity of a Nationwide Rivers Inventory (NRI) River. Screen Summary Compliance Determination This project is not within proximity of a NWSRS river. The project is in compliance with the Wild and Scenic Rivers Act. Supporting documentation Overview and Detail Maps(1).pdf Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 37 of 38 Environmental Justice General requirements Legislation Regulation Determine if the project creates adverse environmental impacts upon a low-income or minority community. If it does, engage the community in meaningful participation about mitigating the impacts or move the project. Executive Order 12898 HUD strongly encourages starting the Environmental Justice analysis only after all other laws and authorities, including Environmental Assessment factors if necessary, have been completed. 1. Were any adverse environmental impacts identified in any other compliance review portion of this project’s total environmental review? Yes  No Based on the response, the review is in compliance with this section. Screen Summary Compliance Determination No adverse environmental impacts were identified in the project's total environmental review. The project is in compliance with Executive Order 12898. This Project will benefit low- and moderate- income persons by providing safe, health, affordable housing in a desirable community and neighborhood. It will allow low- income community members to live in energy efficient housing using alternative energy sources. Supporting documentation Are formal compliance steps or mitigation required? Yes  No Prospect-Place Northampton, MA 900000010239780 02/11/2022 17:19 Page 38 of 38