Public Notice - Final Notice and Public Explanation of Proposed Activity in 100-Year/500-Year Floodplain or Wetland

City of Tallahassee Housing Division

Final Notice and Public Explanation of a Proposed Activity in a 100-Year/500-year Floodplain or Wetland

This is to give notice that the City of Tallahassee, as the Responsible Entity under Part 58, has conducted an evaluation as required by Executive Order 11988 and 11990, in accordance with HUD regulations at 24 CFR 55.20 Subpart C, Procedures for Making Determinations on Floodplain Management and Wetlands Protection.

The full project description is available for review at www.tallha.org. The activity is funded under the Public Housing Program through the Tallahassee Housing Authority (THA).  The proposed site for these activities is within the city limits of the City of Tallahassee, Leon County, Florida. Activities include housing activities on one to four-unit residential structures to include but not be limited to, demolition and new construction. The City participates in the FEMA National Flood Insurance Program and encourages flood insurance on insurable structures. THA expects to conduct these activities on at least 200 units over approximately 29 acres. No units will be located within a wetland or floodway. There are approximately 151,466 acres of 100-year and 500-year floodplains within Leon County. This work will only affect those acres that lie within the City's jurisdiction which can be found online at https://www.tlcgis.org/. A map of the floodplains is available with the project description.

The City has considered the following alternatives and mitigation measures to be taken to minimize adverse impacts and to restore and preserve natural and beneficial values.

(i) All of the reasons why the action must take place in a floodplain:

The main intent of the City's housing programs is to promote new housing stock and preserve existing housing stock by providing safe, affordable and resilient units for homeowners and residents throughout the City of Tallahassee. Some homeowners/residents in the Tallahassee City limits do reside in neighborhoods and communities located in the 100-year floodplain.  A portion of the public housing units at the Orange Avenue Apartment site were constructed in the floodplain.  The City seeks to serve as much of the eligible City resident population as possible under this program.

(ii) Alternatives considered and reasons for non-selection:

1.  (Option) Demolish the buildings, replace deteriorating infrastructure and rebuild on site.  THA had a physical condition assessment of the units conducted by an engineering firm that concluded that the units on the at the Orange Avenue site qualifies for functional and cost obsolescence.  The assessment concluded that the level of repairs needed and/or functional obsolescence observed at the property warrants consideration for demolition and redevelopment, versus significant rehabilitation based upon the estimated cost of repairs for the immediate needs of the property.  All current residents would be relocated to other available public housing units or issued housing choice vouchers. Lastly, no new units will be rebuilt in the floodplain.

2.  (Alternative) Perform substantial rehabilitation activities in the 100-year floodplain and the 500-year floodplain but not the floodway or wetland and consider options for optimizing new construction in a floodplain but not the floodway or wetland. The units at Orange Avenue property were constructed in 1971, with few modernizations or rehabilitations.  Marshall and Swift valuation service provide a published Economic Life of wood framed buildings at 50 years and would need to meet the current building code.  The estimate for substantial rehabilitation is just over 76% of the total development cost to rebuild.  Rehabilitation of the circa 1971 structures would require environmental remediation requirements relative to hazardous building materials (asbestos, lead and mold).

3. (Alternative) "No Action." Perform no project at all. This last option is not a reasonable course of action to take since there are possible alternatives to consider.  There are units currently built in the floodplain that experience water intrusion if there is rain for an extended period.  The sanitary waste lines are reported to be original cast iron that has exceeded its life expectancy and require replacement.  The water supply system to the units is also beyond its life expectancy and water leaks in walls and underground are common.  Options 1 through 3 would comply with regulations even if they are not ideal. There is simply no reason from a floodplain compliance perspective to avoid doing anything. Such an alternative would pass up an opportunity to serve the residents, surrounding neighborhoods, and community residents.

(iii) all mitigation measures to be taken to minimize adverse impacts and to restore and preserve natural and beneficial functions:

Work to be performed, while it will occur in the 100-year floodplain and the 500-year floodplain, will not take place in the floodway, since the housing activity of demolition and reconstruction, are not a functionally dependent use (i.e. a dam, marina, waterfront park, or other structure or activity that that directly depended on water) per 24 CFR 55. Please note that the following requirements will be applicable if any of the following activities are undertaken:

Elevation standards for new construction, repair of substantial damage, or substantial improvement. Elevation standards apply to new construction, repair of substantial damage, or substantial improvement of structures located in an area delineated as a special flood hazard area or land located within the 100-year floodplain. Substantial improvements to residential homes and reconstruction activities within the 100-year flood plain must be elevated and activities will adhere to the local design standards and mitigation requirements. Applicable State, federal, local, and tribal codes and standards for floodplain management that exceed these requirements, including elevation, setbacks, and cumulative substantial damage requirements, will be followed.

In addition to local codes, all state, federal, and local requirements will be followed in the course of the work to be performed. Impacts to the floodplain will be limited due to the expected activities occurring on previously disturbed/developed land. Best management practices for soil erosion and stormwater management will be applied through minimum construction standards. Final and conditional LOMR's or LOMA's from FEMA will be acknowledged as applicable on a case by case basis once sites are selected, if they have been issued for any of the subject properties.

Program activities including demolition and reconstruction are being evaluated through a tiered environmental review. The broad-level review will be a multi-year tiered review which will be valid for five (5) program years after the issuance of the Authority to Use Grant Funds (AUGF), barring any major changes in the program and/or in environmental conditions. The City has reevaluated the alternatives to building in the floodplain/wetland and has determined all practicable alternatives as applicable to the type of projects that may occur.  Environmental files that document compliance with steps 3 through 6 of Executive Orders 11988 and 11990, are available for public inspection, review and copying upon request at the times and location delineated in the last paragraph of this notice for receipt of comments. 

There are three primary purposes for this notice.  First, people who may be affected by activities in floodplains and wetlands and those who have an interest in the protection of the natural environment should be given an opportunity to express their concerns and provide information about these areas.  Second, an adequate public notice program can be an important public educational tool. The dissemination of information and request for public comment about floodplains and wetlands can facilitate and enhance Federal efforts to reduce the risks and impacts associated with the occupancy and modification of these special areas. Third, as a matter of fairness, when the Federal government determines it will participate in actions taking place in floodplains and wetlands, it must inform those who may be put at greater or continued risk.

Written comments must be received by the City on or before Monday, April 19, 2021 and may be sent by U.S. Mail to: City of Tallahassee; 301 S. Adams Street, B-27; Tallahassee, Florida; Attention: Jean Amison, Housing Division Manager, Responsible Entity Designee. Comments may also be submitted by email.  A full description of the project may be viewed online at www.tallha.org or reviewed in person upon request by appointment.

Date: Saturday, April 10, 2021