Prospect Place Environmental AssessmentEnvironmental 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 Entity):
Point of Contact:
Consultant (if applicable):
Point of Contact:
Project Location:
Planning and Sustainability, Northampton, MA 01060
Additional Location Information:
N/A
Direct Comments to:
NChung@NorthamptonMA.gov
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.
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:
Funding Information
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
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 Improvement Act of 1990 [16 USC 3501]
( 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 compliance with the Coastal Barrier Resources Act.
Coastal Barrier Resources Act
Coastal Barrier Resources Act, as amended by the Coastal Barrier Improvement Act of 1990 [16 USC 3501]
( 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 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.
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 redevelopment. The project is in compliance with Executive Order 11988.
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 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.
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 affordable units in a community in which lower income households are often priced out.
Demographic Character Changes / Displacement
1
The Project will increase the economic diversity in Northampton by providing 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.
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 (Uploaded on
section 2005 - "Contamination and Toxic Substances - Multifamily and Nonresidential Properties" Supersedes the SWCA preliminary asbestos report)
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 (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:
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
183BW21076 SPEC SECTION 020810 DisturbanceofLeadCadmiumChromium.pdf
183BW21076 SPEC Asbestos and PCB Abatement.pdf
Supporting documentation on completed measures
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
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)
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
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?
Yes
(
No
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
Are formal compliance steps or mitigation required?
Yes
(
No
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
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.
(
Yes, adverse environmental impacts can be eliminated through mitigation. Document and upload all mitigation requirements below.
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?
Complete removal
(
Risk-based corrective action (RBCA)
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
EBI Property Condition Assessment 20210218.pdf
EBI Phase I ESA 20210218.pdf
Are formal compliance steps or mitigation required?
Yes
(
No
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
MA Estimated Habitats on 737 Bridge Rd.pdf
Are formal compliance steps or mitigation required?
Yes
(
No
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.
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
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
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?
(
No
Based on the response, the review is in compliance with this section.
Yes
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
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/CFR-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:
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."
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.
Supporting documentation
MHC PNF for 737 Bridge Rd Northampton.pdf
MHC Clearance Letter 20220126.pdf
Are formal compliance steps or mitigation required?
Yes
(
No
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
(
No
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
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
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
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