A

GSGSA
A
GSA
GSA Southeast Sunbelt Region

U.S. General Services Administration

U.S..
Southeast Sunbelt Region
Determination of No Practicable Alternative
Anniston, AL — New Federal Courthouse
Introduction
The United StatesStates
The United General
General Services
Services Administration
Administration (GSA),S), Southeast SunbeltRegion,
SoutheastSunbelt Region, hashas
selected
selectedBlock
Block148
148for theconstruction
forthe constructionofofaanew federalcourthouse
newfederal courthousein inAnniston, Al. The
Anniston,Al. Thesite
siteisiswithin
within
the GSA site acquisition budget for its design and construction,
the GSA site acquisition budget for its design and construction, and isand is located
located within
within the
the Federal
Federal
Emergency Management
Emergency Agency(FEMA)
Management Agency (FEMA)100-year floodplain. itit isis bounded
100-yearfloodplain. bounded by 12th Street,
by 12th Street, to
to the
the
south by 11th Street, to the east by Gurnee Avenue, and to the west by Moore Avenue.
Federal regulations require that sites for federal courthouses must be located above the FEMA
500-year flood plain unless there is no practicable alternative to doing so because they are defined as
"critical actions." In accordance with Executive Order 11988, Floodplain Management, GSA must
identify and evaluate practicable alternatives to locating in or affecting the 500-year floodplain.
Practicable alternatives are those that are available to GSA and capable of being implemented within
existing constraints, such as cost, existing technology, and logistics, considering pertinent natural
(topography, habitat, hazards, etc.), social (aesthetics, historic and cultural values, land use patterns,
etc.), economic (cost of space, construction, services, relocation, etc.) and legal (deeds, leases, etc.)
factors. Blocks 149 and 151/159 were identified as possible alternatives to Block 148, but after
evaluation, have been determined to not be practicable alternatives to Block 148.
The action conforms to applicable State and local floodplain protection standards and
mitigation measures will be designed to meet those standards. The action will affect beneficial
floodplain values, thus significant efforts will be considered during design and construction process to
mitigate floodplain impacts either by directing flow, raising surface elevation, or providing flood
protection barriers in accordance with the standard industry practice and in conformance with state
and local floodplain protection standards. As part of the National Environmental Policy Act (NEPA)
process, a draft environmental assessment was distributed to several stakeholders including local,
state and federal agencies and various individuals who possibly have an interest in this project.
Detail listing of agencies and individuals involved can be found in the final Environmental Assessment
dated July 12, 2018 (the EA).

11.S. Services ices Administration

U.S. General Services Administration
Martin Imo Luther King Building
7
Forsyth Street
7 7 Forsyth
Atlanta
\llama GA 36303 30303
w
w w w. gsa.gsa.gov
gsa
 This document explains GSA's findings of no practicable alternative. A description of the
significant facts considered for each site is provided as well as the public review/input received.
Mitigation measures, including how the proposed action will be designed or modified to minimize
harm to or within the floodplain, is also provided.
Background/Facts
According to the FEMA Flood Insurance Rate Map (FIRM) Community Panel 01015C0312E,
effective March 16, 2016, significant portion of Block 148, also known as the City Hall site
(approximately 80%), is located within the floodplain. Constructing a federal courthouse on Block 148
would occur in and stimulate the development of a floodplain. In accordance with the Executive
Order 11988, Floodplain Management, GSA followed its 8-step process, which included identifying
alternatives to developing in the floodplain, identifying impacts due to locating a site in the floodplain,
seeking public comments, identifying floodplain mitigation measures for consideration, and
determining if the alternatives considered are practicable. Details can be found in the EA. Blocks
149 and Block 151/159 were identified and evaluated as alternatives to developing in the floodplain.
GSA held a public meeting on December 21, 2016, to discuss the proposed sites for the new federal
courthouse. Several newspaper articles about the project were published by the Anniston Star
newspaper in December, 2016, which informed the community of the proposed project. GSA
solicited comments on the draft environmental assessment through mailing a letter dated September
18, 2017, as well as a posting in the Anniston Star dated September 20, 2017. The comments
received were incorporated into the EA. In one of the correspondences, the Regional Director of the
National Park Service suggested that of the three alternative building sites, the Block 149 Site would
be the least appropriate, as the demolition of the historic small-scale commercial structures on that
block would adversely affect the ability of the adjacent Freedom Riders National Monument to
"convey its historic associations" and damage its "integrity of setting."
The EA, which included Phase I and Phase II Environmental Site Assessments (ESA),
identified the impacts (indirect, direct, and cumulative) of constructing the federal courthouse in the
floodplain and the mitigation measures that could be undertaken to minimize potential threats to
natural and beneficial floodplain values. On August 8, 2018, the final EA and Finding of No
Significant Impact (FONSI) were published. Below is a brief description of each site:
1. Block 149 Site
Block 149 is approximately 4.04 acres and located immediately south of the Block 148 site and
is bound to the north by 11th Street, to the south by 10th Street, to the east by Gurnee
Avenue, and to the west by Moore Avenue. The Block 149 Site consists of approximately 90%
buildings and other impervious surfaces, with three small vacant lots. This site is divided into
fourteen separate parcels, and also contains two alleys running east to west. Approximately
1% of the Block 149 site overlaps with the FEMA designated 1% Annual Chance floodplain
and 0.2% Annual chance floodplain. Since design of the courthouse would not occur within
this 1% overlap, no structures would be within the floodplain and there would be no
impact. The direct negative effect would be caused by demolition of fourteen historic
structures. During the public review period, the National Park Service suggested that of the
three alternative building sites, the Block 149 Site would be the least appropriate. Moreover, an

General Services Administration

Administration ministration
Martin Luther King Building
77 Forsyth tit Street
Atlanta. G.\ MI 30 7413
03
www. gov
 internal GSA estimate of the cost to acquire the site determined that the acquisition of this site
would significantly exceed the remaining site acquisition budget for this project.
2. Block 151/159 Site
This site encompasses approximately 3.9 acres within the Anniston Urban Core. This site is
bound to the north by West 14th Street, to the south by 13th Street (partially), to the east by
Moore Avenue, and to the west by the eastern portion of the Chief Ladiga Trail right-of-way.
The site currently contains four buildings and a city street. Similar to Block 149, acquisition of
this site would not occur in or stimulate the development of the floodplain. Approximately 40%
of this site currently comprises semi-natural cover (e.g.., grass and bushes). Construction of a
courthouse on this site would remove some of this "water storing" capacity. Additionally, as
per the hydrology study summarized in the EA, this site would have greater surface runoff
impact compared to other sites. Also, impact on soil contamination would be greater as
compared to the Block 148 and Block 149 sites, as explained in the Phase II ESA. It would
also be located approximately two blocks from the center of the governmental community in
Anniston, and also present greater security concerns because of the surrounding
neighborhood. As per the security assessment (details in the EA) performed for this project,
this is the least desirable of the three sites from a security standpoint. The rationale presented
was the fact that the site is adjacent to the Zinn Park, Proposed Chief Ladiga Trail, Reddy Ice
plant and future proposed residential development adjacent to the property. In addition, the
internal GSA cost estimate determined that acquisition of this site would also exceed the
remaining site acquisition budget for this project.
3. Block 148 Site
The Block 148 site, also known as the City Hall site, encompasses an entire city block
(approximately 4.43 acres) within the Anniston Urban Core. The site is bound to the north by
12th Street, to the south by 11th Street, to the east by Gurnee Avenue, and to the west by
Moore Avenue. The site is located approximately two blocks west of the existing courthouse.
At this site, the three existing buildings on the site would be demolished, and a new courthouse
constructed. Based on the current FEMA floodplain map, approximately 80% of the site is
located in the 100 year floodplain due to possible sheet flooding. However, the internal GSA
estimate of the cost to acquire this site determined that acquisition of this site is within the
remaining site acquisition budget for this project.
Determination
The only practicable alternative is the Block 148 site and to develop in the floodplain, because
Block 148 is the only site within the site acquisition budget. Despite its floodplain location, it poses
lesser soil contamination impact than Block 151/159 based on the Phase II ESA, lesser security risk
compared to other two sites based on data presented in the EA, and lesser hydraulic impact based
on the summary of the study provided in the EA. While it also has the potential for an indirect
negative affect to the Freedom Riders National Monument, such potential affect will be mitigated
through consultation with the National Park Service and other stakeholders.

U.S.
U.S.. General SERVICES
Services Administration
Luther King Building
77 Street
Atlanta,
Atlanta 30303
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 With regard to Block 149, although this site would not be in the floodplain, it exceeds the site
acquisition budget, making its selection not a practicable alternative. Additionally, it poses a major
negative impact on cultural resources due to demolition of several historic structures, and indirect
negative affect to the Freedom Riders National Monument, unlike Block 148, which only poses a
moderate impact. Based on the contamination data presented in the Phase II ESA, remediation
efforts would also be more than those for Block 148.
Finally, Block 151/159 is not a practicable alternative because it too exceeds the site
acquisition budget. In addition, it sits away from the government community, poses security and
water runoff risk to the new courthouse, and has greater impact due to soil contamination as
compared to Block 148, according to the data in the EA.
Mitigation Measures:
For the design and construction phases of the federal courthouse project, mitigation measures
to alleviate potential floodplain impacts will be considered and pursued. Some of these measures
have been identified in the EA. Listed below are those measures that will be considered during the
design and construction phases:
Raise the surface elevation of the new building above the floodplain elevation (in this instance
above the 500-year base flood level) based on the local and FEMA standards through filling
and other appropriate measures.
Use non-corrosive materials below the potential water surface elevation at the structure.
Apply water resistant coatings to concrete and other materials below the potential water
surface elevation at the structure.
Incorporate green spaces and the use of natural materials on the site to improve and control
water drainage.
Grade the area around the building to direct flow away from and/or around the building.
Use low permeable materials below the potential water surface elevation at the structure.
Use of flood protection barriers such as flood gates, flood doors, flood panels, etc, if
appropriate.
Conclusion

After evaluating alternatives, including costs, impacts and minimization opportunities, GSA has
determined that the proposed action to select Block 148 for the construction of a new federal
courthouse in Anniston, AL, is the practicable alternative. Although this selection will occur in and
stimulate development of a floodplain, mitigation measures have been identified to alleviate potential
floodplain impacts. Since this site is within the remaining site acquisition budget, it is GSA's
determination that there is no other practicable alternative to Block 148.

U.S. General Services Administration

1i Martin Luther King Building
Forsyth Street
Atlanta GA 30111
w w ww. gov
Recommended By:

8/13
Ashish Desai, P.E.., LEED AP Date
Environmental Manager
Southeast Sunbelt Region
General Services Administration

Approved By:

e Goodwin
Goodwin in Date
Re
Regionalal Commissioner
S • east Sunbelt Region
Southeast
General Services Administration
General

U.S. General
General SerServices
vices 1'8' ices Administration
Adminstratioin ration
Martin Luther
1Luther King Building
77 Forsyth
Fors, Suet Street
Atlanta,
Atlanta, GA OA 30303
www.gsa.gov v