Lyman Terrace Comment Response

8/2/2019 Lyman Terrace Comment Response

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Response to Public CommentsEnvironmental Review RecordLyman Terrace DemolitionlDispositionHolyoke Housing Authority

HolyokeMAMarch 28, 2012

SummaryofLyman Terrace Housing Complex,1

o 58.43( c), the City of Holyoke hereby responds to public comments received in response to the NoticefFinding ofNo Significant ImpactlNotice of ntent to Request Approval ofProperty Demolition and Dispositionissued for the Environmental Review Record (ERR) for the demolition/disposition of the LymanThe RE has prepared a revised version of the Environmental Assessment

of some impact levels, clear identification ofof the reasoning for its assessment.

of Holyoke Office for Community Development (OCD) prepared the ERR as the Responsible Entity (RE)The Holyoke Housing Authority is the Recipient, as defined by 58.2(a)(5), of federal

ofHUD funds and. This is important to note because the proposed project is demolition and disposition of the

y- not new construction, acquisition, or substantial rehabilitation.2 is documentation of an objective information gathering process from a number

knowledgeable sources including federal, state and local agencies and reputable environmental firms.Once the required information was compiled, the RE reviewed it to determine whether it

3 which would trigger additional review via an Environmental Impactt (EIS).4 The RE determined that the gathered information did not reveal site, environmental or other(1) prohibit federal funds from being utilized for this project or at this site as the result of a

of an EIS."No Significant Impact" and "human environment" may be alarming or even

5 , respectively, and incorporated by statute into the

acknowledges community sentiment in opposition to the demolition ofLyman Terrace. This ERRof the housing complex and interaction between localment and the community. However, it is the RE's responsibility to complete the Environmental Review

of its abilities and to submit it to HUD as one step in the multi step process required by HUD forof a public housing complex.6 Completion of the ERR and HUD's release of the

of all public comments, the finding remains No Significant Impact.of

of an Environmental Impact Statement.

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Response to Public Commentsin the Office for Community

and at the administrative office of the Holyoke Housing Authority. A sign-in list was kept for publicof the Environmental Review Record at OCD.7

ommunity Development is located on the fourth floor ofCity Hall Annex and is handicapped(no stairs). In fact, the City ofHolyoke Retirement Board, which has aof disabled/infirm visitors, is located on the second floor of the Annex. One commenter noted difficulty in

stairwell to access the elevator.8

re submitted to the Office for Community Development via email, fax, first class mail andOnly comments received by the Office for Community Development and the Holyoke Housing

to herein. In the FONSIINOI, it was suggested that commenters confirm receipt of theirNo commenters called to confirm receipt of their comments.

offorty seven people submitted fifty public comments to the Office for Community Development.9 Sixteenfrom Lyman Terrace residents. Three City Councilors submitted comments. Three

of demolition. Comments were received from residents ofHolyoke,Springfield, Amherst, and Worthington. Many commenters did not provide their mailing addresses.Terrace resident visited the OCD office regarding his re-housing concerns and was provided with

by Nilka Ortiz, Mayoral Aide during his meeting with OCD staff. With theofMs. Ortiz providing translation and dictation service, he submitted a written statement.

in Spanish. English translation ofthose comments wasby Nilka Ortiz, Mayoral Aide and the English version is attached to the original submittal.

ous field observations were made since Fall 2011 in the development of the ERR. RE staff responsible forof the ERR have a combined 35+ years of professional planning, community development, and

in the City ofHolyoke. Lyman Terrace is within walking distance of theoffice and is visible from the RE's office windows on the fourth floor ofCity Hall Annex. Both preparers areofLyman Terrace.

ent was reviewed for topics related to the Environmental Review in compliance with 58.75 bystaff members including the Administrator, Deputy Administrator and Office Manager to ensure that

in this response. Public comments were generally related tohistorical significance, displacement/relocation, proper publication/notification and uture

ofsite.

is provided herein.Historical Significance

mment excerpts: "Historical, socially vibrant housing units""Lyman Terrace is historical" "Lyman Terrace is historic and should bepreserved." "Oldest projects in the country." "Urge the Holyoke HistoricalCommission to find Lyman Terrace of historical significance" "Would like forERR to make a revision about Lyman Terrace that will be fair because theseprojects are 72 years old" "Lyman Terrace has historical significance" "Historicallandmark" "One of the oldest public housing developments in the nation" "Deephistorical significance"

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Response: In compliance with Section 106, the MA State Historic Preservation Officer (MASHPO) at the Massachusetts Historical Commission (MHC) was consulted andresponded on December 28, 2011 that "i t has been determined that this project isunlikely to affect significant historic or archeological resources". 10The RE, not the HHA, provided MHC with a standard packet of objectiveinformation required by MHC for project reviews. This included an explanatorycover letter, photographs, site maps, project addresses and the MHC ProjectNotification Form. Materials submitted to MHC did note two factors raised bycommenters- the fact that Lyman Terrace was built in 1938 (and is therefore over50 yrs. old) and that Lyman Terrace was the first public housing site in Holyoke. 11MHC did not request additional information, although, by their own complianceguidance, could have. 12The Holyoke Historical Commission (HHC) was provided with three opportunitiesto comment. On December 9,2011, the HHC received a copy of the MHC packetby certified mail which was signed for by HHC Chairman Olivia Mausel. HHCmet with the Holyoke Housing Authority in a public meeting on January 4,2012 todiscuss the project. On February 17, 2012, HHC received the Finding ofNoSignificant Impact and Request for Release ofFunds Notice via certified mailsigned for by Wistariahurst Museum staff.On March 12, 2012, the HHC submitted a letter to Mayor Morse and the CityCouncil.!3 The HHC letter did not provide information contrary to MHC findingsnor did it provide substantive historical information. The RE provided HUDEnvironmental Review Process training to the HHC in October 2010 and the HHChas commented on other HUD environmental reviews. HHC's own Bylawsindicate that they "wiII cooperate with and advise .... he Office CommunityDevelopment. ,!4Two commenters noted that Lyman Terrace is not historically significant.The RE asserts that the ERR is in full compliance with Section 106 and 24 CFRPart 58 for review of historic and archeological resources.

Displacement and Relocation PlanComment Excerpts:

Response:

"Relocation Plan states that there would be no additional Section 8 vouchers tohelp relocate displaced residents." "Displacement." "Decreases neighborhoodaccessibility to the poor." "Additional studies on how residents will be housed.""No clear plan to replace it." "Relocation plan is completely inadequate." "Notenough vouchers for tenants." "Neighborhood gentrification." "Importantresource to low-income individuals" "The failure to acknowledge this mixedeffect (displacement) means no planning has gone into how to mitigate negatives""Have not received a lot of orientation (Section 8)" "Plan has not given us enoughtime or options" "We haven't had a meeting to tell us they were thinking ofdemolishining (sic) these buildings" "The City ofHolyoke .. .offer fair andaffordable housing to all its residents"

Displacement of tenants is acknowledged in the Environmental Review Record onthe Environmental Assessment Checklist.

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in that tenants will be provided withimproved housing conditions.t displacement may also be potentially adverse forat Lyman Terrace.

of relocation on their ability toservices (medical, retail, educational etc.) and their ability toordable housing. However, BUD does not provide a compliance standard(except at 58.37 with a threshold of2500 or more units affectedImpact Statement).dbook 1390.2, Page 5-21, the RE has revised the

and notes that the project is subject to the standards ofthe Uniformct. To reduce the potentially adverse stresses of relocation on tenants,of up to 180 days for

if needed. This recommendation is based upon public commentslimited availability of local affordable housing units dueof foreclosures in the Pioneer Valley and recent natural disasters whichin surrounding municipalities.

information distribution with the MA FairCenter, Holyoke MA.ISofthe Holyoke Housing Authority's Relocation Plan and its

BUDis not the topic of this process. Approval of the Relocation Plan and

HHA's compliance with the Uniform Relocation Act is the responsibility ofThe RE makes no judgments as to the appropriateness or legality of theo note that there will be displacement as a result of thisrules and16

Holyoke Housing Authority provided the RE with a Relocation Plan on5, 2011 via email. That version was incorporated into the ERRof the public comments related to the inadequacy of the December 5,11 Relocation Plan, the Housing Authority provided the final version of theon March 2, 2012. The March 2, 2012 version is now


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Lyman Terrace is mapped within an Environmental Justice neighborhood- a factthat is acknowledged and documented in the Environmental Review Record, on theEnvironmental Assessment Form, the Statutory Checklist and mapping. Becausetenants are being displacedfrom an Environmental Justice neighborhood, asopposed to being moved to an Environmental Justice neighborhood, no furtherreview is necessary. 18The RE asserts that the ERR is in compliance with 24 CFR Part 58 for the topics ofdisplacement and environmental justice.

Proper PublicationlNotificationComment Excerpts: "HHA failed to publish "the plan" adequately.""Open meetings and discussions with affected residents""Inadequate effort to inform tenants about the "plan"". "Tenants report being misinformed." "No public discussion or comment has been taken." "A dialogue hasto be opened" "Only two meetings were held" "Lack of adequate inclusion ofresidents" "Extend public comment period"

Response: In compliance with 58.43, the Office for Community Development disseminatedthe FONSIINOI notice via several methods including:

Po stings on the City ofHolyoke and Holyoke Housing Authority's web sites (with two page projectdescription); Publication on February 17,2012 in the Legal Ads Section ofThe Republican newspaper; First class mailings to forty six abutters within 300' of the site; Certified mailing to Sonia Gonzalez, President of the Lyman Terrace Tenant Association(English/Spanish); Posted with the Holyoke City Clerk (English/Spanish) on February 15,2012; Posted in the lobby of the administrative office of the Holyoke Housing Authority (English/Spanish); and First class mailings to ten federal, state, local and regional agencies.

Numerous public meetings were held by the HHA regarding the future ofLymanTerrace. Copies of agendas and sign-ins are incorporated into the ERR todocument public participation. These include: March 5, 2012 Tenants Meeting November 9,2011 Tenants Association Meeting September 15,2011 Community Meeting September 28, 2011 Notification Letter of Demolition Program to Tenant Association August 3,2011 Community Meeting November 8, 2010 Community Meeting November 3,2010 Community Meeting October 12, 2010 Community Meeting September 29,2010 Community Meeting

rity has continued its outreach to tenants including distribution of information about their14, 2012.Tenant Association President Sonia Gonzalez was provided with a certified letter from the REINOI Notice- English/Spanish) offering to discuss the matter or to meet with her. Ms. Gonzalezcomments on behalf of herself.

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parties distributed materials to the tenants during the public comment period. The materials didis not handicapped accessible. 19

compliance with 58.45, an eighteen day public comment period was provided from February 17,2012 through7, 2012. In accordance with 58.46, Mayor Morse extended the public comment period to thirty days. Theon March 23,2012. An extension notice was posted with the City Clerk and on the

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RE asserts that the ERR is in compliance with 24 CFR Part 58 regarding public notifications and commentFurther, the RE notes that the number of commenters is indicative of the broad community knowledge andabout the project.

Future Development/Use of SiteComment Excerpts: "Land sold to private developers and not re-used for housing" "Sold off in smallerparcels to avoid empty trash strewn lot" "Abandoned the plan for use ofHOPE VIfunds."

E Response: The ERR specifically excludes future uses of the property from the scope ofreview. The ERR acknowledges that any proposed use must comply with Part 58if federal funds are utilized.

Other Comments

The Holyoke Housing Authority has issued a Request for Proposals21 forredevelopment of the site. Potential developers are provided with the option ofpurchasing the property "as-is" or purchasing the land after the HHA demolishesthe buildings.One commenter noted that HOPE VI funds should be used for rehabilitation ofLyman Terrace. The HHA applied for Hope VI in 2010 but the application wasnot funded. The Hope VI program has since been eliminated from the federalbudget. The Holyoke Housing Authority in partnership with the Holyoke Planningand Economic Development Office applied for a 2011 HUD ChoiceNeighborhoods Grant for rehabilitation/redevelopment ofLyman Terrace and itssurrounding neighborhood; Lyman Terrace was not chosen.

. Tenant Concerns/Evictions/Property ConditionsAll public comments were provided to the Holyoke Housing Authority includingthose raising concerns about current living conditions (peeling paint, rustywindows, vermin, broken doors/windows).One tenant raised concerns about an unrelated eviction process and was referred bythe RE to the MA Justice Project22 and the MA Fair Housing Center23 for tenantassistance.

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. Hazards and NuisancesOne commenter noted that the Tighe & Bond Phase I Environmental Assessmentraised two HREC's (Historical Recognized Conditions) which would result in afinding of "potentially adverse". The RE notes that the site is a currently occupiedfederalized housing site and that it has been occupied since 1938 and has beensubject to numerous HUD inspections.Careful reading ofTighe and Bond's Phase I Environmental Assessment indicatesthat (1) no underground storage tanks remain on the subject property as determinedby a 2003 NEE assessment and (2) there was not a release from the former UST'sas determined by a 2003 NEE assessment.Furthermore HUD technical guidance provides that a Phase I is required if theplanning party can not assert that the property is not contaminated. In this case, aPhase I was completed and the finding by a licensed site professional (LSP)indicates that "Tighe & Bond recommends no further investigations at this time".The RE asserts that the Environmental Assessment is consistent with therequirements of 58.5(i) and is also consistent with the HUD technical assistancefor hazards, toxic, or radioactive substances. 24 The assessment of "No ImpactAnticipated" is correct because potentially adverse conditions have been reviewedby Tighe & Bond and Tighe & Bond recommended no further investigations(which indicates that the identification of a potentially adverse site condition(s) hasbeen addressed). A qualified professional (Tighe & Bond) was utilized to conductthe investigations. Furthermore, it is HUD's policy to ensure that occupants ofproposed sites are not adversely affected. In this case, the occupants are already atthe site and the site is being proposed for demolition.

c. Compatibility with Surrounding Development, Visual Quality & Demographic/Neighborhood CharacterChanges & Noise

. City Council Resolution

RE Response:

Community Petition

One commenter noted that the responses to the categories ofCompatibility withSurrounding Development, Visual Quality, Noise and Demographic/NeighborhoodCharacter Changes were deficient. The RE has revised the EnvironmentalAssessment to include additional information in each of three categories.

A draft resolution in opposition to the demolition of Lyman Terrace wasintroduced to the City Council by Councilor Kevin 10urdain?5 It was referred tothe Redevelopment Committee of the City Council for consideration on March 29,2012.The draft resolution does not raise any environmental issues not previouslyaddressed in this response. The RE recommends that the Holyoke HousingAuthority consider the Resolution during its application to the HUD SpecialApplication Center, Chicago.

A community petition in opposition to the demolition of Lyman Terrace wassubmitted during the public comment period. Not all petition pages weresubmitted at the same time and are filed according to the date received. 26

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RE Response: The community petition does not raise any environmental issues not previouslyaddressed in the ERR. The RE has provided a copy of the petition to the HolyokeHousing Authority for consideration during its application to the HUD SpecialApplication Center, Chicago.

1. The Holyoke Housing Authority shall comply with all applicable federal, state, and local laws andregulations, including but not limited to, the Uniform Relocation Act and MA Department ofEnvironmental Protection demolition and asbestos disposal (i f present) regulations.

2. All written materials, publications and correspondence issued by the Holyoke Housing Authority to thetenants of Lyman Terrace relative to their relocation or displacement or alternative housing options orthe future ofLyman Terrace shall be provided in English and Spanish.

3. Within thirty days of receipt of the Release of the Environmental Grant Certification from HUD, theHolyoke Housing Authority shall distribute "Fair Housingfor Individuals Receiving Public orHousing Assistance" brochures produced by the MA Fair Housing Center to each household/familytenant at Lyman Terrace. Brochures shall be provided in English and Spanish.

4. To ensure that all Lyman Terrace tenants are provided with access to third-party unbiased professionallegal assistance relative to their fair housing rights, the Holyoke Housing Authority shall coordinatetwo general informational meetings between the MA Fair Housing Center and Lyman Terrace tenantswithin thirty days of receipt of the Release of the Environmental Grant Certification from HUD. Onemeeting shall be during normal business hours and one meeting shall be in the evening or a weekendday. Tenants shall be notified of the meeting in writing by the Holyoke Housing Authority and saidnotice shall be provided in English and Spanish. Meeting notices shall be distributed at least seventytwo hours in advance and shall be posted at least seventy two hours in advance with the Holyoke CityClerk, in the administrative offices of the Housing Authority, on the Housing Authority's website, andin community spaces at Lyman Terrace. The Holyoke Housing Authority shall ensure thatprofessional translation services are available for the meeting.

5. The RE strongly recommends a housing search extension of up to 180 days for tenants, if needed. Thisrecommendation is based upon public comments concerning the potential limited availability of localaffordable housing units due the number of foreclosures in the Pioneer Valley and recent naturaldisasters which destroyed affordable housing options in surrounding municipalities.

6. The Holyoke Housing Authority shall comply with the City of Holyoke Erosion Control Ordinance.Appropriate erosion control, dust control, and vermin control shall be utilized during demolition andpost-demolition.

7. The Holyoke Housing Authority shall comply with the City of Holyoke Stormwater ManagementOrdinance and the EPA Stormwater Pollution Prevention Plan (NPDES) requirements to ensure thatthe site is well managed during demolition and that there are no stormwater impacts.

8. Upon demolition of any portion of the project site and if site activity shall remain inactive for thirtydays or more, the site or demolished portion thereof shall be graded, loamed and seeded with aperennial seed mix to ensure adequate vegetative cover so as to prevent erosion or dust prior toredevelopment. The Holyoke Housing Authority shall maintain the site post-demolition including bimonthly mowing to prevent overgrowth and woody vegetation and trash/debris removal to ensure thatthe site does not become blighted prior to redevelopment.

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9. To abate potential temporary noise increases during the demolition so as to decrease disturbance of theneighborhood, the RE strongly recommends daytime demolition work, quieter construction equipment,and quieter demolition operations. (ie- no brick crushing operations at site).

ClosingThe RE has carefully considered each set of public comments. Revisions to theERR have been made accordingly. The RE and Recipient look forward to HUD'sreview of the environmental review process.

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or http://portal.hud.gov/hudportalldocuments/huddoc?id=DOC 8699.pdfof federal laws and standards reviewed.

1508:shall be interpreted comprehensively to include the natural and physical environment and the relationship

people with that environment. (See the defmition of "effects" ( 1508.8 ).) This means that economic or social effects areof an environmental impact statement. When an environmental impact

is prepared and economic or social and natural or physical environmental effects are interrelated, then theof these effects on the human environment .. (40 CFR 1508.14)

ofno significant impact means a document by a Federal agency briefly presenting the reasons why an action, not 1508.4 ), will not have a significant effect on the human environment and for which an environmentalIt shall include the environmental assessment or a summary of it and shall note

it ( 1501. 7(a)(5) ). Ifthe assessment is included, the finding need not repeatof the discussion in the assessment but may incorporate it by reference. (40 CFR 1508.13)

orud.gov/hudportaIIHUD?src=/program offices/public indian housing/centers/sac/demo dispo for additional

of public housing.of the ERR file review sign in list is included in the original ERR file and has been provided to HUD.to tenants indicated that the City Hall Annex building is not accessible.of each public comments (and supporting material if submitted) is included in the original ERR file and has been

March 27, 2012 http://www.sec.state.ma.us/mhc/mhcrevcom/revcomidx.htmFederal Review

Any projects that requirefunding, licenses, or perm its from federal agencies must be reviewed in compliancewith Section 106 of he National Historic Preservation Act of1966. Section 106 requires federal agencies totake into account the effects of heir actions on historic properties. "Section 106 review, "follows a specificprocess, which is guided by federal regulations (36 CFR 800). These regulations have created a series ofsteps by which federal agencies identify and evaluate historic properties that may be affected by theirundertakings, assess adverse effects to those properties, and take prudent andfeasible measures to avoid,minimize, or mitigate those effects. In Massachusetts, these steps are taken in consultation with theMassachusetts State Historic Preservation Officer (SHPO). The MHC is the office of he SHPo. Otherinterested parties such as local historical commissions or Indian Tribes are also consulted

See Page 1 of the MHC Project Notification Form.March 27, 2012 http://www.sec.state.ma.us/mhc/mhcrevcom/revcomidx.htm

"What will MHC do with a completed PNF, and how long will it take?Once received at MHC, the PNF will be reviewed by our professional staff. Within 30 days ofreceipt, MHC will respond in writing. The response will include information on

whether there are known or anticipated historic or archaeological properties withinthe project area,whether the project is likely to affect historic or archaeological properties,whether further MHC review is warranted,

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whether additional information is needed to assess the likelihood that historic orarchaeological properties will be affected by the proposed project,

whether an archaeological surveyor historic study of the property is warranted,and what, if any, avoidance or mitigation measures may be appropriate.

If, after review of the PNF submittal and MHC files, MHC determines that the project is unlikely toaffect significant historic or archaeological resources, MHC review is complete. If the MHC doesnot respond within 30 days, the project may proceed as planned."

A copy of the HHC letter and OCD response are included in the original ERR file and provided to HUD.27, 2012 http://www.holyoke.org/images/stories/dept_about_holyoke/Revised_Bi-Laws_9-1-10.docSee the Revised Environmental Assessment for details.For additional information on tenants' rights and the Housing Authority's responsibilities under the Uniform Relocation Act,see www.hud.gov or http://www.hud.gov/offices/cpdlaffordablehousing/training/web/relocationloverview.cfm Foron implementing relocation and tenants' rights, please see

A copy of the HHA materials distributed on March 1,2012 is in the original ERR file and has been provided to HUD.March 27, 2012 http://portal.hud.govlhudportaIIHUD?src=/program_offices/commylanning/environment/review/justiceIs the project located in a neighborhood or community where the proposed action is likely to raiseenvironmental justice issues?

Threshold: Executive Order 12898 - "Federal Actions to Address Environmental Justice in Minority Populations andLow-Income PopUlations," applies in low-income or minority neighborhoods where the grantee proposes theacquisition of housing, the acquisition ofland for development, and new construction. Environmental justice issuesmay include, but are not limited to new, continued or historically disproportionate potential for high and adversehuman health and environmental effects on minority or low-income populations. The grantee will need to determine ifthe site or neighborhood suffers from disproportionate adverse health and environmental effects relative to thecommunity at large. [http://www.epa.gov/oswer/ej/html-doc/execordr.htm]

A copy of the non-governmental materials is in the ERR file and has been provided to HUD.A copy of the public comment period extension notice posting stamped by the City Clerk is in the original ERR file and hasd to HUD.27, 20 12 http://www.holyokehousing.org/sites/defaultifiles/Lyman%20Terrace%20Redevelopment_ O.pdfMA Justice Project 413-533-2660

MA Fair Housing Center 413-539-9796

27, 2012 http://portal.hud.govlhudportaIIHUD?src=/program_offices/commylanning/environmentlreviewlhazardousA copy of the City Council Resolution is in the original ERR file and has been provided to HUD.A copy of the Community Petition is in the original ERR file and has been provided to HUD.

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Environmental Assessmentfor HUD-funded Proposals

Demolition of Lyman Terrace Housing ComplexCity of Holyoke Office for Community DevelopmentLinda B. McQuade, AdministratorAlicia M. Zoeller, Deputy AdministratorCity of Holyoke Office for Community DevelopmentMarch 28, 2012 (Revised in Response to Public Comments)

inpublic comments. They are presented together in this one document forin distribution and review. No substantive information has been changed.

in the first version are now cited herein. Documentation supportingin the Environmental Review Record.

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Environmental AssessmentEntity: City of Holyoke Office for Community Development

Mayor Alex B. MorseDemolition of Lyman Terrace Housing Complex

Bounded by John, Front, and Lyman Streets, Holyoke MAproject addresses in ERR.$1.6 million

Holyoke Housing Authority475 Maple Street, Holyoke MA 01040

Rosalie Deane, Executive Director413-539-2220

(List all mitigation measures adopted by the responsible entity to eliminate orThese conditions must be included in project contracts and other relevantts as requirements). [24 CFR 58.40(d), 40 CFR 1505.2(c)]1. The Holyoke Housing Authority shall comply with all applicable federal, state, and local lawsand regulations, including but not limited to, the Uniform Relocation Act and MA Departmentof Environmental Protection demolition and asbestos disposal (if present) regulations.2. All written materials, publications and correspondence issued by the Holyoke HousingAuthority to the tenants of Lyman Terrace relative to their relocation or displacement oralternative housing options or the future of Lyman Terrace shall be provided in English andSpanish.3. Within thirty days of receipt of the Release of the Environmental Grant Certification fromHUD, the Holyoke Housing Authority shall distribute "Fair Housing for Individuals ReceivingPublic or Housing Assistance" brochures produced by the MA Fair Housing Center to eachhousehold/family tenant at Lyman Terrace. Brochures shall be provided in English andSpanish.4. To ensure that all Lyman Terrace tenants are provided with access to third-party unbiasedprofessional legal assistance relative to their fair housing rights, the Holyoke HousingAuthority shall coordinate two general informational meetings between the MA Fair Housing

Center and Lyman Terrace tenants within thirty days of receipt of the Release of theEnvironmental Grant Certification from HUD. One meeting shall be during normal businesshours and one meeting shall be in the evening or a weekend day. Tenants shall be notified

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of the meeting in writing by the Holyoke Housing Authority and said notice shall be providedin English and Spanish. Meeting notices shall be distributed at least seventy two hours inadvance and shall be posted at least seventy two hours in advance with the Holyoke CityClerk, in the administrative offices of the Housing Authority, on the Housing Authority'swebsite, and in community spaces at Lyman Terrace. The Holyoke Housing Authority shallensure that professional translation services are available for the meeting.5. The RE strongly recommends a housing search extension of up to 180 days for tenants, ifneeded. This recommendation is based upon public comments concerning the potential

limited availability of local affordable housing units due the number of foreclosures in thePioneer Valley and recent natural disasters which destroyed affordable housing options insurrounding municipalities.6. The Holyoke Housing Authority shall comply with the City of Holyoke Erosion ControlOrdinance. Appropriate erosion control, dust control, and vermin control shall be utilizedduring demolition and post-demolition.7. The Holyoke Housing Authority shall comply with the City of Holyoke StormwaterManagement Ordinance and the EPA Stormwater Pollution Prevention Plan (NPDES)

requirements to ensure that the site is well managed during demolition and that there are nostormwater impacts.8. Upon demolition of any portion of the project site and if site activity shall remain inactive forthirty days or more, the site or demolished portion thereof shall be graded, loamed andseeded with a perennial seed mix to ensure adequate vegetative cover so as to preventerosion or dust prior to redevelopment. The Holyoke Housing Authority shall maintain thesite post-demolition including bi-monthly mowing to prevent overgrowth and woodyvegetation and trash/debris removal to ensure that the site does not become blighted prior toredevelopment.9. To abate potential temporary noise increases during the demolition so as to decreasedisturbance of the neighborhood, the RE strongly recommends daytime demolition work,quieter construction equipment, and quieter demolition operations. (ie- no brick crushingoperations at site).


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[5B.40(9)]

X* Finding of No Significant Impact(The project will not result in a significant impact on the quality of thehuman environment)Finding of Significant Impact(The project may significantly affect the quality of the human environment)

RE notes that the regulatory threshold for preparation of an Environmental Impacta Finding of Significant Impact is demolition of 2500(24 CFR 58.37(a)(2)) This proposal is for demolition of 167units- a factor 1115 of the regulatory threshold.

Date:l!3m/9b(;).,strator ame/Title/Agency: City of Holyoke Office for Community DevelopmentApproving Official Sign

LI da cQuade, AdministratorCity of Holyoke Office for Community Development

of Purpose and Need for the Proposal: [40 CFR 150B.9(b)]is obsolete as

no reasonable program for modification is cost effective to return them useful life. Factors considered in this determination include theize, outdated unit and site utilities and infrastructure, non-accessibility, energy in-efficiencies,poor site drainage. The Housing Authority asserts that the units do not meet housing

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of the Proposal: Include all contemplated actions which logically areer geographically or functionally a composite part of the project, regardless of theof funding. [24 CFR 58.32, 40 CFR 1508.25]of the

of the property by the Holyoke Housing Authority or others have not been determined andthe subject of this Environmental Assessment. The RE notes that the Holyoke Housing Authorityof Lyman Terrace. The RFP can beon line at www.holyokehousing.org.

Describe the existing conditions of the project areain the absence of the project. [24 CFRan existing occupied federalized public housing complex located in the downtown core

MA. It was built in 1938 as the first public housing complex in Holyoke.of 167 units and one HHA office in eighteen buildings on a 5.5 acre parcel013-01-001). The buildings are brick, two story and aligned in terraced rows. The complex isd by John, Front, and Lyman Streets. It is located in Census Tract 8117, Block Group 2.is located in one of four Center City neighborhoods- the Prospect Heights/Downtown ofIt is zoned Downtown Residential (DR) and is surrounded by various land uses. To the south islarge concrete parking garage and abandoned blighted building (30 John Street). To the north ont, there are commercial and mixed uses including a banquet facility. Further west on alongelderly housing complexes and a condo complex. To the east along Front Street, are

ant former mill buildings as well as social service offices. To the west, the property is boundedof buildings along High Street.of services and amenities including, governmental

le Street- PVTA).&Market Characteristics Report for The Center Cityin 3840 households

of the City's population. Housing estimates indicate a supply of 4400in Center City representing 26% of the City's supply. 560 units were vacant for a vacancy rate ofApproximately 90% of the occupied housing units were rentals including a large supply of

US Census Bureau- 2005-2009 American Community Survey, Census Tract 8117 hashousing units- 890 of which are occupied and 163 which are vacant. 88.3% (786) of occupiedtal and 11.7% (104) of occupied units are owner occupied. The demolition of 167 units atof occupied rental housing units in Census Tract 8117 by 21 %The median rent in Census Tract 8117 is $429.


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to the 2011 FFIEC Census Report, the demographics for the Center City Census Tracts are as

Center City Households Tract Tract Hispanic Tract %Census Population Minority % Population Hispanic % BelowTracts PovertyLine8114 889 2534 85.67% 2109 83 % 49.498115 637 2169 93.13% 1929 89% 50.888116 1129 3560 90.59% 3089 87% 48.328117 1080 2346 72.46% 1588 68% 49.04

US Census Bureau- 2000 Census, 89.7% of residents in Census Tract 8117 are low ormoderate income. In Block Group 2,90.7% of residents are low/moderate income.Lyman Terrace has been identified in previous applications for HUD assistance as severely distressedhousing. The Holyoke Housing Authority has made several applications to the Hope VI Program andmost recently an application to the Choice Neighborhoods Program. Lyman Terrace was not selected forither program by HUD and the Hope VI Program has since been eliminated in the federal budget. HUDon several occasions and one visit was highlighted in the HUD New

ngland News, Volume 2, Issue 5, September 2011 Newsletter.of Holyoke has undertaken an urban renewal process for Center City. The proposed Urbanenewal Plan is expected to be submitted to the Commonwealth of MA for approval in Spring 2012. In

of the Urban Renewal Plan, the City in consultation with VHB, Inc. conducted a five monthin the 2009 Center City Vision Plan. Regarding Lyman Terrace, theenter City Plan includes a Vision Plan Element to "Restore the Urban Neighborhoods" with the followingnitiatives: -Continue initiatives to stabilize current housing and introduce new housing options,ncluding moderately priced housing to complement the existing affordable housing in these areas.-Support Holyoke Housing Authority's application for Hope VI funds to reconstruct theyman Terrace complex and the development of housing within a 3 mile radius.-Target for rehabilitation key vacant residential units that have valuable architectural

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Statutory Checklist[24CFR 58.5]Record the determinations made regarding each listed statute, executive order or regulation. Provide appropriatesource documentation. Note reviews or consultations completed as well as any applicable permits or approvalsobtained or required. Note dates of contact or page references. Provide compliance or consistency documentation.Attach additional material as appropriate. Note conditions, attenuation or mitigation measures required.

Factors Determination and Compliance DocumentationHistoric Preservation MA SHPO - "Unlikely to affect significant historic"

CFR 800L Source: MHC 12/28/2011Floodplain Management Zone C.24 CFR 55, Executive Order 11988] Source: FEMA FirmeUe- Panel 4 of 8- 1979Wetlands Protection Site does not contain wetlands and is more than 100' from

[Executive Order 11990] nearest water body (Holyoke Canal System)Source: DEP Wetlands MappingCoastal Zone Management Act Inland MA[Sections 307(c), (d)] Source: Google Map of MASole Source Aquifers Not in designated Sole Source Aquifer[40 CFR 149] Source: www.epa.gov and Tighe & Bond, Phase I

Environmental Site Assessment- Page 2-2Endangered Species Act Not in Priority Habitat or Estimated Habitat[50 CFR 402] Source: MA NHESP Mapping and Tighe & Bond, Phase IEnvironmental Site Assessment- Page 2-2Wild and Scenic Rivers Act None designated in Holyoke.[Sections 7(b), (c)] Source: www.rivers.govAir Quality No SIP's identified in Holyoke. Project does not propose any[Clean Air Act, Sections 176(c) new construction at this time.and (d), and 40 CFR 6, 51, 93] Source: www.epa.govSee Condition No.1 for air quality protection if asbestosmitigation is needed.Farmland Protection Policy Act Urban core- no farmland on or adjacent to site.

[7 CFR 658] Source: Tighe & Bond, Phase I Environmental SiteAssessment- Page 2-1Environmental Justice Within an EJ designated area.[Executive Order 12898] Source: MA Oliver Map and Tighe & Bond EJ MapHUDE t I Sta d dDt t"Vlronmen a n ar s e ermlna Ion andC rmpllance Documentat" n0Noise Abatement and Control Proposal is for demolition and disposition- not new[24 CFR 51 B] construction or substantial rehab. See Condition No.9 for

Mitigation.Toxic/Hazardous/Radioactive Presently an occupied HUD-assisted public housing project;Materials, Contamination, demolition is proposed. Phase I recommends "no furtherChemicals or Gases investigations at this time."[24 CFR 58.5(i)(2)] Source: Tighe & Bond, Phase I Environmental SiteAssessment- January 20,2012Siting of HUDAssisted No HUD assisted project is proposed for siting. Project isProjects near Hazardous demolition of an existing housing complex.Operations [24 CFR 51 C]Airport Clear Zones and Not within Clear Zone or Accident Pot Zone; existingAccident Potential Zones federalized housing project.[24 CFR 51 D] Source: Westover Joint Land Use Contours Map2002 Land Noise Contours & Westfield Barnes Study Update


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Environmental Assessment Checklist[Environmental Review Guide HUO CPO 782, 24 CFR 58.40; Ref. 40 CFR 1508.8 &1508.27]

Evaluate the significance of the effects of the proposal on the character, features and resources of the project area.Enter relevant base data and verifiable source documentation to support the finding. Then enter the appropriateimpact code from the following list to make a determination of impact. Impact Codes: (1) - No impact anticipated;(2) - Potentially beneficial; (3) - Potentially adverse; (4) - Requires mitigation; (5) - Requires project modification.Note names, dates of contact, telephone numbers and page references. Attach additional material as appropriate.Note conditions or mitigation measures required.Land Development Code Source or DocumentationConformance with 1 (1) This ERR is for demolition/disposition only and it is not withinComprehensive Plans and Zoning the scope of this ERR to evaluate future use of the site. Futureuse would undergo its own stringent environmental and land usereview which would ensure that it is compatible and feasible alongwith adherence to land use and zoning ordinances.(2) The HHA RFP requires that future use of the property beconsistent with the forthcoming Urban Renewal Plan.Compatibility and Urban Impact 1 (1) This ERR is for demolition/disposition only and it is not withinthe scope of this ERR to evaluate future use of the site. Future

use would undergo its own stringent environmental and land usereview which would ensure that it is compatible and feasible alongwith adherence to land use and zoning ordinances.(2) The HHA RFP requires that future use of the property beconsistent with the forthcoming Urban Renewal Plan.Slope Flat urban area surrounded by pavement. Buildings are terraced.1 High point on west side of parcel sloping down to the east.Source: Tighe & Bond, Phase I Environmental Site Assessment-Page 2-2Erosion 4 Requires compliance with Holyoke Erosion Control Ordinance

during and post demolition. See Conditions Nos.5, 8Soil Suitability 1 Urban land.Source: Tighe & Bond, Phase I Environmental Site Assessment-Page 2-2Hazards and Nuisances including 1 Project complies with 58.5(i)(2)(1) and HUD Technical GuidanceSite Safety Source: Tighe and Bond, Phase I Assessment January 20,2012Page 4-2- No further investigations at this time.Energy Consumption 1 Removal of substandard housing with outdated utilitiesSource: Holyoke Housing Authority Justification

Noise - Contribution to 1 Demolition resulting in vacant lot will not increase communityCommunity Noise Levels noise level because there will be no land use therefore no noisegenerated at the site. See Condition NO.9 for noise abatementduring demolition.Air Quality No SIP's identified in Holyoke. Project does not propose any newEffects of Ambient Air Quality on 4 construction at this time.Project and Contribution to Source: www.epa.govCommunity Pollution Levels See Condition No.1 for air q u a l i ~ o t e c t i o n if asbestos is presentEnvironmental Design (1) This ERR is for demolition/disposition only and it is not withinVisual Quality - Coherence, 1 the scope of this ERR to evaluate future use of the site. FutureDiversity, Compatible Use and use would undergo its own stringent environmental and land useScale review which would ensure that it is compatible and feasible alongwith adherence to land use and zoning ordinances.

(2) The HHA RFP requires that future use of the property beconsistent with the forthcoming Urban Renewal Plan. (3)


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Compliance with Section 106 has been met (visual quality).Source: MHC 12/28/2011

Socioeconomic Code Source or DocumentationDemographic Character Changes 2/ See below for description.

3Displacement 4 Project will displace tenants in 167 units.Mitigation: Uniform Relocation Act requirements. Relocation Plan

See Condition Nos. 1, 3, 4, 5Employment and Income Patterns 1 65.4% of persons over 16 yo in Census Tract 8117 are not in theworkforce.Source: US Census Bureau 2005-2009 American CommunitySurveyDemographic Character ChangesThe relocation of 400 residents from Lyman Terrace will result in demographic character changes.Whether those changes are described as potentially beneficial or potentially adverse is a polarizing topic.Some may argue that deconcentrating poverty and an EJ population is potentially beneficial. Others mayargue that it results in gentrification of the urban core. There are no compliance standards, federallegislation or standards for measuring deficiency or impacts for this factor.The following calculations for Census Tract 8117 assume (1) demolition with no replacement housing; (2)that 98% (392) of 400 Lyman Terrace tenants are Hispanic (as reported by one commenter); (3) that100% of the 400 residents are low or moderate income (LIM) and (4) that all Lyman Terrace residentsrelocate to areas outside of Census Tract 8117.

Existing/Pre-Demolition Post-Demolition2011 Tract population 2346 1946 (2346-400)2011 Tract Hispanic Pop_ulation 1588 1196 (1588-392)2011 Tract Hispanic % 68% 61%2000 Tract Population 2310 1910 (2310-400)2000 Tract LIM Population 2073 1673 (2073-400)L/M % 89.7% 87.5%Data Sources:2011 Data from FFIEC2000 Data from US Census Bureau- 2000 CensusHUD Handbook 1390.2

Community Facilitiesand ServicesEducational Facilities*Commercial Facilities

Health Care*Social Services*Solid WasteWaste Water

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Code13

114

1

Source or DocumentationProject does not increase need for educational facilities.The loss of 167 units may result in a reduction in foot traffic to thecommercial corridor in downtown. HUD provides no compliancestandards for this category.Source: Public comments regarding use of downtownretail/commercial facilitiesProject does not increase need for health care.Project does not increase need for social services.See Condition No.1 for disposal of demolition debris.Demolition debris must be handled in accordance with MA DEPRegulations to prevent adverse effects.Site is serviced by municipal waste water.Source: Tighe & Bond, Phase I Environmental Site Assessment-


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Page 2-1Storm Water 4 Project must comply with City of Holyoke Stormwater Ordinanceand EPA NPDES SWPPP for work on sites greater than 5 acres.See Condition NO.7.Water Supply 1 Site is serviced by public water supply.Source: Tighe & Bond, Phase I Environmental Site Assessment-Page 2-2Public Safety 1 Project does not increase need for police.

- Police- Fire 1 Project does not increase need for fire.- EmelRencyMedical 1 Project does not increase need for EMS.Open Space and Recreation 1 Project results in no loss of open space.- Open Space- Recreation 1 Project results in no loss of recreational facilities.

- Cultural Facilities 1 Project results in no loss of cultural facilities.Transportation 1 Project results in no loss of transportation resources nor does itburden existing transportation resources.*The RE recognizes that the tenants' access to these services may be impacted by this project. However this ERR isreviewing the impacts of the proposal on each of the community facilities. For example if 167 units/400 people weremoving into an area, these services, if already overburdened, may be further impacted.

Natural Features Source or DocumentationWater Resources 1 None within 100' of site.Sources: Tighe &Bond Aerial Photo Parcel MapDEP Priority Resource MaQSurface Water 1 None within 100' of site.Sources: Tighe &Bond Aerial Photo Parcel MapDEP Priority Resource Map_Unique Natural Features and 1 Urban core- no farmland on or adjacent to site.Agricultural Lands Source: Tighe & Bond, Phase I Environmental SiteAssessment- Page 2-1Vegetation and Wildlife 1 Urban well-developed siteSource: Tighe & Bond, Phase I Environmental SiteAssessment- Page 2-2

Other Factors Source or DocumentationFlood Disaster Protection Act 1 Flood Insurance not required. Zone C.[Flood Insurance] Source: FEMA FirmeUe- Panel 4 of 8- 1979. 58.6(a)]Coastal Barrier Resources Act! I Inland MACoastal Barrier Improvement Act Over 50 miles from coastal areas[58.B{c)]Airport Runway Clear Zone or I Not within Clear Zone or Accident Pot ZoneClear Zone Disclosure Source: Westover Joint Land Use Contours Map[58.6(d)] 2002 Land Noise ContoursOther Factors


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of Findings and ConclusionsTO THE PROPOSED ACTION[24 CFR 58.40(e), Ref. 40 CFR 1508.9]

of action that were considered and not selected, such as other sites, designor other uses of the subject site. Describe the benefits and adverse impacts to the human environmenteach alternative and the reasons for rejecting it.)

in previous applications for HUD assistance as severely distressedThe Holyoke Housing Authority has made several applications to the Hope VI Program andrecently an application to the Choice Neighborhoods Program. Lyman Terrace was not beenVI Program has since been eliminated in the federal. HUD officials have visited Lyman Terrace on several occasions and one visit was highlighted in

2, Issue 5, September 2011 Newsletter.[24 CFR 58.40(e)]

of not implementing the preferred alternative).

te. Tenants would remain in severely distressed housing. However, tenants would notnot be subject to the potentially adverse stresses associated with relocationunfamiliar surroundings, separation from family/friends/services, etc.).

[24 CFR 58.40(d), 40 CFR 1508.20]in which the proposal or its external factors should be modified in order to minimize

of Sources, Agencies and Persons Consulted [40 CFR 1508.9(b)]addition to the sources referenced herein and those provided in the ERR, the following sources were1.2.3.

4.5.6.7.8.

9.10.

US Census Bureau- 2000 CensusUS Census Bureau- 2005-2009 American Community Survey2011 FFIEC Census Report Summary Census- Summary Census Income and CensusPopulation Information MSAMD: 44140 Springfield MA (Federal Financial InstitutionsExamination Council)Holyoke's Center City Vision Plan Prepared by VHB on behalf of the City of Holyoke and theHolyoke Redevelopment Authority. August 2009.HUD New England News Volume 2 Issue 5 (September 2011) Retrieved March 28, 2012from http://portal.hud.gov/hudportal/documents/huddoc?id=20 10-08-03.pdf 0Request for Proposals Retrieved multiple dates from www.holyokehousing.orgBaseline Economic Conditions and Market Characteristics- The Center City Urban RenewalDistrict Holyoke, Massachusetts Prepared by RKG Associates, Inc. October 2010The Environmental Review Process Retrieved multiple dates fromhttp://www.nls.gov/offices/cpd/affordablehousing/training/web/crosscutting/environmental/reviewstage1.cfm24 CFR Parts 51 & 58Environmental Assessment Guide for Housing Projects Retrieved multiple dates fromhttp://www.hud.gov/offices/adm/hudclips/handbooks/cpdh/1390.2/index.cfm

Documents

Lyman Terrace Comment Response