Response to Public Comments

Environmental Review Record

Lyman Terrace DemolitionlDisposition
Holyoke Housing Authority
HolyokeMA
March 28, 2012
Summary
The Environmental Review Record for the demolition and disposition of Lyman Terrace Housing Complex,
Holyoke MA has been completed in accordance with 24 CFR Part 58.
1
Pursuant to 58.43( c), the City of Holyoke hereby responds to public comments received in response to the Notice
of Finding of No Significant ImpactlNotice of Intent to Request Approval of Property Demolition and Disposition
(FONSIINOI) issued for the Environmental Review Record (ERR) for the demolition/disposition of the Lyman
Terrace Housing Complex, Holyoke MA. The RE has prepared a revised version of the Environmental Assessment
which addresses submitted public comments including reclassification of some impact levels, clear identification of
data and sources relied on, and detailed statements of the reasoning for its assessment.
The City of Holyoke Office for Community Development (OCD) prepared the ERR as the Responsible Entity (RE)
as defined by 58.2(a)(7). The Holyoke Housing Authority is the Recipient, as defined by 58.2(a)(5), of federal
funds.
The Lyman Terrace site is an occupied federalized public complex which has been the recipient ofHUD funds and
inspections for decades. This is important to note because the proposed project is demolition and disposition of the
property- not new construction, acquisition, or substantial rehabilitation.
The Environmental Review Record
2
is documentation of an objective information gathering process from a number
of knowledgeable sources including federal, state and local agencies and reputable environmental firms.
Information for this ERR was gathered from on-line government agency mapping sources and consultation with
subject matters experts. Once the required information was compiled, the RE reviewed it to determine whether it
revealed site, environmental or other factors
3
which would trigger additional review via an Environmental Impact
Statement (EIS).4 The RE determined that the gathered information did not reveal site, environmental or other
factors that would either (1) prohibit federal funds from being utilized for this project or at this site as the result of a
compliance action or (2) require the preparation of an EIS.
The RE recognizes that the words "No Significant Impact" and "human environment" may be alarming or even
offensive to some people; however, both phrases are legal terms originating from the National Environmental
Policy Act and defined at 40 CFR 1508.13 and 40 CFR 1508.14
5
, respectively, and incorporated by statute into the
environmental review process (24 CFR 58.4).
The RE acknowledges community sentiment in opposition to the demolition of Lyman Terrace. This ERR
generated unprecedented dialogue about the future of the housing complex and interaction between local
government and the community. However, it is the RE's responsibility to complete the Environmental Review
Record to the best of its abilities and to submit it to HUD as one step in the multi step process required by HUD for
demolition/disposition of a public housing complex.
6
Completion of the ERR and HUD's release of the
environmental grant condition does not compel the Housing Authority to move forward with demolition/disposition
and does not supplant other federal, state and local laws like relocation planning or tenants' rights.
The RE confirms that after careful consideration of all public comments, the finding remains No Significant Impact.
This finding is based upon the fact that compliance factors in 24 CFR Part 58 have been met and that the scale of
the project does not rise to the level of an Environmental Impact Statement.
1
Response to Public Comments
The Environmental Review Record was made available for public viewing in the Office for Community
Development and at the administrative office of the Holyoke Housing Authority. A sign-in list was kept for public
review of the Environmental Review Record at OCD.7
The Office for Community Development is located on the fourth floor of City Hall Annex and is handicapped
accessible by elevator from the ground level (no stairs). In fact, the City of Holyoke Retirement Board, which has a
number of disabled/infirm visitors, is located on the second floor of the Annex. One commenter noted difficulty in
navigating a stairwell to access the elevator.
8
Public comments were submitted to the Office for Community Development via email, fax, first class mail and
hand delivery. Only comments received by the Office for Community Development and the Holyoke Housing
Authority are responded to herein. In the FONSIINOI, it was suggested that commenters confirm receipt of their
comments with OCD. No commenters called to confirm receipt of their comments.
A total offorty seven people submitted fifty public comments to the Office for Community Development.
9
Sixteen
comments were received from Lyman Terrace residents. Three City Councilors submitted comments. Three
commenters wrote in explicit support of demolition. Comments were received from residents of Holyoke,
Chicopee, Springfield, Amherst, and Worthington. Many commenters did not provide their mailing addresses.
A Lyman Terrace resident visited the OCD office regarding his re-housing concerns and was provided with
English-Spanish translation service by Nilka Ortiz, Mayoral Aide during his meeting with OCD staff. With the
assistance of Ms. Ortiz providing translation and dictation service, he submitted a written statement.
Several commenters submitted their public comments in Spanish. English translation ofthose comments was
provided by Nilka Ortiz, Mayoral Aide and the English version is attached to the original submittal.
Numerous field observations were made since Fall 2011 in the development of the ERR. RE staff responsible for
the preparation of the ERR have a combined 35+ years of professional planning, community development, and
environmental permitting experience in the City of Holyoke. Lyman Terrace is within walking distance of the
RE's office and is visible from the RE's office windows on the fourth floor of City Hall Annex. Both preparers are
intimately familiar with downtown Holyoke and the surroundings of Lyman Terrace.
Each public comment was reviewed for topics related to the Environmental Review in compliance with 58.75 by
three RE staff members including the Administrator, Deputy Administrator and Office Manager to ensure that
comments were adequately captured and addressed in this response. Public comments were generally related to
four themes- historical significance, displacement/relocation, proper publication/notification and future
development/use of site.
A response to each theme is provided herein.
1. Historical Significance
Public comment excerpts: "Historical, socially vibrant housing units"
"Lyman Terrace is historical" "Lyman Terrace is historic and should be
preserved." "Oldest projects in the country." "Urge the Holyoke Historical
Commission to find Lyman Terrace of historical significance" "Would like for
ERR to make a revision about Lyman Terrace that will be fair because these
projects are 72 years old" "Lyman Terrace has historical significance" "Historical
landmark" "One of the oldest public housing developments in the nation" "Deep
historical significance"
2
RE Response: In compliance with Section 106, the MA State Historic Preservation Officer (MA
SHPO) at the Massachusetts Historical Commission (MHC) was consulted and
responded on December 28, 2011 that "it has been determined that this project is
unlikely to affect significant historic or archeological resources". 10
The RE, not the HHA, provided MHC with a standard packet of objective
information required by MHC for project reviews. This included an explanatory
cover letter, photographs, site maps, project addresses and the MHC Project
Notification Form. Materials submitted to MHC did note two factors raised by
commenters- the fact that Lyman Terrace was built in 1938 (and is therefore over
50 yrs. old) and that Lyman Terrace was the first public housing site in Holyoke. 11
MHC did not request additional information, although, by their own compliance
guidance, could have.
12
The Holyoke Historical Commission (HHC) was provided with three opportunities
to comment. On December 9,2011, the HHC received a copy of the MHC packet
by certified mail which was signed for by HHC Chairman Olivia Mausel. HHC
met with the Holyoke Housing Authority in a public meeting on January 4,2012 to
discuss the project. On February 17, 2012, HHC received the Finding of No
Significant Impact and Request for Release of Funds Notice via certified mail
signed for by Wistariahurst Museum staff.
On March 12, 2012, the HHC submitted a letter to Mayor Morse and the City
Council.!3 The HHC letter did not provide information contrary to MHC findings
nor did it provide substantive historical information. The RE provided HUD
Environmental Review Process training to the HHC in October 2010 and the HHC
has commented on other HUD environmental reviews. HHC's own Bylaws
indicate that they "wiII cooperate with and advise .... the Office Community
Development. ,,!4
Two commenters noted that Lyman Terrace is not historically significant.
The RE asserts that the ERR is in full compliance with Section 106 and 24 CFR
Part 58 for review of historic and archeological resources.
2. Displacement and Relocation Plan
Public Comment Excerpts:
RE Response:
"Relocation Plan states that there would be no additional Section 8 vouchers to
help relocate displaced residents." "Displacement." "Decreases neighborhood
accessibility to the poor." "Additional studies on how residents will be housed."
"No clear plan to replace it." "Relocation plan is completely inadequate." "Not
enough vouchers for tenants." "Neighborhood gentrification." "Important
resource to low-income individuals" "The failure to acknowledge this mixed
effect (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 enough
time or options" "We haven't had a meeting to tell us they were thinking of
demolishining (sic) these buildings" "The City of Holyoke ... offer fair and
affordable housing to all its residents"
Displacement of tenants is acknowledged in the Environmental Review Record on
the Environmental Assessment Checklist.
3
Displacement was originally identified on the Environmental Assessment
Checklist as "potentially beneficial" in that tenants will be provided with
opportunities for improved housing conditions.
The RE acknowledges that displacement may also be potentially adverse for
tenants forced to relocate from their homes after many years at Lyman Terrace.
Many commenters raised concerns about the impact of relocation on their ability to
access much needed services (medical, retail, educational etc.) and their ability to
find affordable housing. However, BUD does not provide a compliance standard
for displacement (except at 58.37 with a threshold of2500 or more units affected
to trigger an Environmental Impact Statement).
Consistent with BUD Handbook 1390.2, Page 5-21, the RE has revised the
Environmental Assessment Checklist Impact Category for Displacement to "Needs
Mitigation" and notes that the project is subject to the standards ofthe Uniform
Relocation Act. To reduce the potentially adverse stresses of relocation on tenants,
the RE strongly recommends a housing search extension of up to 180 days for
tenants, if needed. This recommendation is based upon public comments
concerning the potential limited availability of local affordable housing units due
the number of foreclosures in the Pioneer Valley and recent natural disasters which
destroyed affordable housing options in surrounding municipalities.
A third Displacement mitigation requirement compels the Holyoke Housing
Authority to coordinate a meeting and information distribution with the MA Fair
Housing Center, Holyoke MA.IS
The content ofthe Holyoke Housing Authority's Relocation Plan and its
compliance with the Uniform Relocation Act and other applicable BUD
regulations is not the topic of this process. Approval of the Relocation Plan and
the HHA's compliance with the Uniform Relocation Act is the responsibility of
BUD. The RE makes no judgments as to the appropriateness or legality of the
Relocation Plan other than to note that there will be displacement as a result of this
project and displacement must be handled in accordance with applicable rules and
regulations. 16
The Holyoke Housing Authority provided the RE with a Relocation Plan on
December 5, 2011 via email. That version was incorporated into the ERR
available for public viewing.
As a result of the public comments related to the inadequacy of the December 5,
2011 Relocation Plan, the Housing Authority provided the final version of the
Relocation Plan to the RE on March 2, 2012. The March 2, 2012 version is now
incorporated into the ERR. The HHA noted its oversight in initially providing the
RE with a draft Relocation Plan.
To address public comments related to the inadequacy of the Relocation Plan and
misinformationiconcern among tenants, Housing Authority staff conducted a door
to door information drop and meeting notification on March 1,2012 at Lyman
Terrace. Tenants were provided additional information about relocation and the
environmental review. 17
On March 5, 2012, the Housing Authority conducted a public meeting to discuss
the Environmental Review and the Relocation Plan with tenants. At the meeting,
HHA officials encouraged residents to contact the HHA directly with any
questions or concerns.
4
Lyman Terrace is mapped within an Environmental Justice neighborhood- a fact
that is acknowledged and documented in the Environmental Review Record, on the
Environmental Assessment Form, the Statutory Checklist and mapping. Because
tenants are being displacedfrom an Environmental Justice neighborhood, as
opposed to being moved to an Environmental Justice neighborhood, no further
review is necessary. 18
The RE asserts that the ERR is in compliance with 24 CFR Part 58 for the topics of
displacement and environmental justice.
3. Proper PublicationlNotification
Public Comment 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 mis-
informed." "No public discussion or comment has been taken." "A dialogue has
to be opened" "Only two meetings were held" "Lack of adequate inclusion of
residents" "Extend public comment period"
RE Response: In compliance with 58.43, the Office for Community Development disseminated
the FONSIINOI notice via several methods including:
Po stings on the City of Holyoke and Holyoke Housing Authority's web sites (with two page project
description );
Publication on February 17,2012 in the Legal Ads Section of The 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 of Lyman
Terrace. Copies of agendas and sign-ins are incorporated into the ERR to
document 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
The Housing Authority has continued its outreach to tenants including distribution of information about their
relocation rights on March 14, 2012.
The Lyman Terrace Tenant Association President Sonia Gonzalez was provided with a certified letter from the RE
(with the FONSIINOI Notice- English/Spanish) offering to discuss the matter or to meet with her. Ms. Gonzalez
submitted comments on behalf of herself.
5
Non-governmental parties distributed materials to the tenants during the public comment period. The materials did
contain errors like notifying the tenants that the City Hall Annex Building is not handicapped accessible.
19
In compliance with 58.45, an eighteen day public comment period was provided from February 17,2012 through
March 7, 2012. In accordance with 58.46, Mayor Morse extended the public comment period to thirty days. The
public comments period closed on March 23,2012. An extension notice was posted with the City Clerk and on the
Office for Community Development's webpage.
2o
The RE asserts that the ERR is in compliance with 24 CFR Part 58 regarding public notifications and comment
periods. Further, the RE notes that the number of commenters is indicative of the broad community knowledge and
engagement about the project.
4. Future Development/Use of Site
Public Comment Excerpts: "Land sold to private developers and not re-used for housing" "Sold off in smaller
parcels to avoid empty trash strewn lot" "Abandoned the plan for use of HOPE VI
funds."
RE Response: The ERR specifically excludes future uses of the property from the scope of
review. The ERR acknowledges that any proposed use must comply with Part 58
if federal funds are utilized.
5. Other Comments
The Holyoke Housing Authority has issued a Request for Proposals
21
for
redevelopment of the site. Potential developers are provided with the option of
purchasing the property "as-is" or purchasing the land after the HHA demolishes
the buildings.
One commenter noted that HOPE VI funds should be used for rehabilitation of
Lyman Terrace. The HHA applied for Hope VI in 2010 but the application was
not funded. The Hope VI program has since been eliminated from the federal
budget. The Holyoke Housing Authority in partnership with the Holyoke Planning
and Economic Development Office applied for a 2011 HUD Choice
Neighborhoods Grant for rehabilitation/redevelopment of Lyman Terrace and its
surrounding neighborhood; Lyman Terrace was not chosen.
SA. Tenant Concerns/Evictions/Property Conditions
All public comments were provided to the Holyoke Housing Authority including
those raising concerns about current living conditions (peeling paint, rusty
windows, vermin, broken doors/windows).
One tenant raised concerns about an unrelated eviction process and was referred by
the RE to the MA Justice Project
22
and the MA Fair Housing Center
23
for tenant
assistance.
6
SB. Hazards and Nuisances
One commenter noted that the Tighe & Bond Phase I Environmental Assessment
raised two HREC's (Historical Recognized Conditions) which would result in a
finding of "potentially adverse". The RE notes that the site is a currently occupied
federalized housing site and that it has been occupied since 1938 and has been
subject to numerous HUD inspections.
Careful reading of Tighe and Bond's Phase I Environmental Assessment indicates
that (1) no underground storage tanks remain on the subject property as determined
by a 2003 NEE assessment and (2) there was not a release from the former UST's
as determined by a 2003 NEE assessment.
Furthermore HUD technical guidance provides that a Phase I is required if the
planning party can not assert that the property is not contaminated. In this case, a
Phase 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 the
requirements of 58.5(i) and is also consistent with the HUD technical assistance
for hazards, toxic, or radioactive substances. 24 The assessment of "No Impact
Anticipated" is correct because potentially adverse conditions have been reviewed
by Tighe & Bond and Tighe & Bond recommended no further investigations
(which indicates that the identification of a potentially adverse site condition(s) has
been addressed). A qualified professional (Tighe & Bond) was utilized to conduct
the investigations. Furthermore, it is HUD's policy to ensure that occupants of
proposed sites are not adversely affected. In this case, the occupants are already at
the site and the site is being proposed for demolition.
Sc. Compatibility with Surrounding Development, Visual Quality & Demographic/Neighborhood Character
Changes & Noise
SD. City Council Resolution
RE Response:
SE. Community Petition
One commenter noted that the responses to the categories of Compatibility with
Surrounding Development, Visual Quality, Noise and Demographic/Neighborhood
Character Changes were deficient. The RE has revised the Environmental
Assessment to include additional information in each of three categories.
A draft resolution in opposition to the demolition of Lyman Terrace was
introduced to the City Council by Councilor Kevin 10urdain?5 It was referred to
the Redevelopment Committee of the City Council for consideration on March 29,
2012.
The draft resolution does not raise any environmental issues not previously
addressed in this response. The RE recommends that the Holyoke Housing
Authority consider the Resolution during its application to the HUD Special
Application Center, Chicago.
A community petition in opposition to the demolition of Lyman Terrace was
submitted during the public comment period. Not all petition pages were
submitted at the same time and are filed according to the date received.
26
7
RE Response: The community petition does not raise any environmental issues not previously
addressed in the ERR. The RE has provided a copy of the petition to the Holyoke
Housing Authority for consideration during its application to the HUD Special
Application Center, Chicago.
6. Special Conditions and Mitigation
1. The Holyoke Housing Authority shall comply with all applicable federal, state, and local laws and
regulations, including but not limited to, the Uniform Relocation Act and MA Department of
Environmental Protection demolition and asbestos disposal (if present) regulations.
2. All written materials, publications and correspondence issued by the Holyoke Housing Authority to the
tenants of Lyman Terrace relative to their relocation or displacement or alternative housing options or
the future of Lyman Terrace shall be provided in English and Spanish.
3. Within thirty days of receipt of the Release of the Environmental Grant Certification from HUD, the
Holyoke Housing Authority shall distribute "Fair Housingfor Individuals Receiving Public or
Housing Assistance" brochures produced by the MA Fair Housing Center to each household/family
tenant 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 professional
legal assistance relative to their fair housing rights, the Holyoke Housing Authority 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 the Environmental Grant Certification from HUD. One
meeting shall be during normal business hours and one meeting shall be in the evening or a weekend
day. Tenants shall be notified of the meeting in writing by the Holyoke Housing Authority and said
notice shall be provided in English and Spanish. Meeting notices shall be distributed at least seventy
two hours in advance and shall be posted at least seventy two hours in advance with the Holyoke City
Clerk, in the administrative offices of the Housing Authority, on the Housing Authority's website, and
in community spaces at Lyman Terrace. The Holyoke Housing Authority shall ensure 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, if needed. This
recommendation is based upon public comments concerning the potential limited availability of local
affordable housing units due the number of foreclosures in the Pioneer Valley and recent natural
disasters 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 and
post-demolition.
7. The Holyoke Housing Authority shall comply with the City of Holyoke Stormwater Management
Ordinance and the EPA Stormwater Pollution Prevention Plan (NPDES) requirements to ensure that
the 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 thirty
days or more, the site or demolished portion thereof shall be graded, loamed and seeded with a
perennial seed mix to ensure adequate vegetative cover so as to prevent erosion or dust prior to
redevelopment. The Holyoke Housing Authority shall maintain the site post-demolition including bi-
monthly mowing to prevent overgrowth and woody vegetation and trash/debris removal to ensure that
the site does not become blighted prior to redevelopment.
8
9. To abate potential temporary noise increases during the demolition so as to decrease disturbance of the
neighborhood, the RE strongly recommends daytime demolition work, quieter construction equipment,
and quieter demolition operations. (ie- no brick crushing operations at site).
7. Closing
The RE has carefully considered each set of public comments. Revisions to the
ERR have been made accordingly. The RE and Recipient look forward to HUD's
review of the environmental review process.
9
1 See www.hud.gov or http://portal.hud.gov/hudportalldocuments/huddoc?id=DOC 8699.pdf
2 See 58.38 for additional information on an Environmental Review Record.
3 See 58.5 and 58.6 for the list of federal laws and standards reviewed.
4 See 58.37 for the circumstances requiring an EIS.
5 From 40 CFR 1508:
Human environment shall be interpreted comprehensively to include the natural and physical environment and the relationship
of people with that environment. (See the defmition of "effects" ( 1508.8 ).) This means that economic or social effects are
not intended by themselves to require preparation of an environmental impact statement. When an environmental impact
statement is prepared and economic or social and natural or physical environmental effects are interrelated, then the
environmental impact statement will discuss all of these effects on the human environment .. (40 CFR 1508.14)
Finding of no significant impact means a document by a Federal agency briefly presenting the reasons why an action, not
otherwise excluded ( 1508.4 ), will not have a significant effect on the human environment and for which an environmental
impact statement therefore will not be prepared. It shall include the environmental assessment or a summary of it and shall note
any other environmental documents related to it ( 1501. 7(a)(5) ). Ifthe assessment is included, the finding need not repeat
any of the discussion in the assessment but may incorporate it by reference. (40 CFR 1508.13)
6 See www.hud.gov or
http://portal.hud.gov/hudportaIIHUD?src=/program offices/public indian housing/centers/sac/demo dispo for additional
information on the demolition and disposition of public housing.
7 A copy of the ERR file review sign in list is included in the original ERR file and has been provided to HUD.
8 Materials distributed by non-governmental parties to tenants indicated that the City Hall Annex building is not accessible.
9 A copy of each public comments (and supporting material if submitted) is included in the original ERR file and has been
provided to HUD.
10
March 27, 2012 http://www.sec.state.ma.us/mhc/mhcrevcom/revcomidx.htm
Federal Review
Any projects that requirefunding, licenses, or perm its from federal agencies must be reviewed in compliance
with Section 106 of the National Historic Preservation Act of 1966. Section 106 requires federal agencies to
take into account the effects of their actions on historic properties. "Section 106 review, "follows a specific
process, which is guided by federal regulations (36 CFR 800). These regulations have created a series of
steps by which federal agencies identify and evaluate historic properties that may be affected by their
undertakings, 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 the
Massachusetts State Historic Preservation Officer (SHPO). The MHC is the office of the SHPo. Other
interested parties such as local historical commissions or Indian Tribes are also consulted
II See Page 1 of the MHC Project Notification Form.
12
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 of
receipt, MHC will respond in writing. The response will include information on



whether there are known or anticipated historic or archaeological properties within
the project area,
whether the project is likely to affect historic or archaeological properties,
whether further MHC review is warranted,
10
whether additional information is needed to assess the likelihood that historic or
archaeological 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 to
affect significant historic or archaeological resources, MHC review is complete. If the MHC does
not respond within 30 days, the project may proceed as planned."
13 A copy of the HHC letter and OCD response are included in the original ERR file and provided to HUD.
14March 27, 2012 http://www.holyoke.org/images/stories/dept_about_holyoke/Revised_Bi-Laws_9-1-10.doc
15 See the Revised Environmental Assessment for details.
16 For additional information on tenants' rights and the Housing Authority's responsibilities under the Uniform Relocation Act,
please see www.hud.gov or http://www.hud.gov/offices/cpdlaffordablehousing/training/web/relocationloverview.cfm For
HUD Handbook 1378 on implementing relocation and tenants' rights, please see
http://portal.hud.gov/hudportaIIHUD?src=/program offices/comm planning/library/relocationlpolicyandguidancelhandbookI3
78
17 A copy of the HHA materials distributed on March 1,2012 is in the original ERR file and has been provided to HUD.
18 March 27, 2012 http://portal.hud.govlhudportaIIHUD?src=/program_ offices/comm ylanning/environment/review/justice
Is the project located in a neighborhood or community where the proposed action is likely to raise
environmental justice issues?
Threshold: Executive Order 12898 - "Federal Actions to Address Environmental Justice in Minority Populations and
Low-Income PopUlations," applies in low-income or minority neighborhoods where the grantee proposes the
acquisition of housing, the acquisition ofland for development, and new construction. Environmental justice issues
may include, but are not limited to new, continued or historically disproportionate potential for high and adverse
human health and environmental effects on minority or low-income populations. The grantee will need to determine if
the site or neighborhood suffers from disproportionate adverse health and environmental effects relative to the
community at large. [http://www.epa.gov/oswer/ej/html-doc/execordr.htm]
19 A copy of the non-governmental materials is in the ERR file and has been provided to HUD.
20 A copy of the public comment period extension notice posting stamped by the City Clerk is in the original ERR file and has
been provided to HUD.
21March 27, 20 12 http://www.holyokehousing.org/sites/defaultifiles/Lyman%20Terrace%20Redevelopment_ O.pdf
22 MA Justice Project 413-533-2660
http://www.majp.org/
23 MA Fair Housing Center 413-539-9796
http://www.massfairhousing.org/
24March 27, 2012 http://portal.hud.govlhudportaIIHUD?src=/program_ offices/comm ylanning/environmentlreviewlhazardous
25 A copy of the City Council Resolution is in the original ERR file and has been provided to HUD.
26 A copy of the Community Petition is in the original ERR file and has been provided to HUD.
11
Project Identification:
Preparer:
Responsible Entity:
MonthlYear:
Environmental Assessment
for HUD-funded Proposals
Demolition of Lyman Terrace Housing Complex
City of Holyoke Office for Community Development
Linda B. McQuade, Administrator
Alicia M. Zoeller, Deputy Administrator
City of Holyoke Office for Community Development
March 28, 2012 (Revised in Response to Public Comments)
The Statutory Checklist and Environmental Assessment Checklist have been revised in
response to public comments. They are presented together in this one document for
ease in distribution and review. No substantive information has been changed.
Sources relied upon in the first version are now cited herein. Documentation supporting
the statements and findings herein are in the Environmental Review Record.
The Responsible Entity has also provided a Response to Public Comments.
3/28/2012
1
Environmental Assessment
Responsible Entity: City of Holyoke Office for Community Development
[24 CFR 58.2(a)(7)]
Certifying Officer: Mayor Alex B. Morse
[24 CFR 58.2(a)(2)]
Project Name: Demolition of Lyman Terrace Housing Complex
Project Location: Bounded by John, Front, and Lyman Streets, Holyoke MA
See individual project addresses in ERR.
Estimated Total Project Cost: $1.6 million
Grant Recipient: Holyoke Housing Authority
[24 CFR 58.2(a)(5)]
Recipient Address: 475 Maple Street, Holyoke MA 01040
Project Representative: Rosalie Deane, Executive Director
Telephone Number: 413-539-2220
Conditions for Approval: (List all mitigation measures adopted by the responsible entity to eliminate or
minimize adverse environmental impacts. These conditions must be included in project contracts and other relevant
documents 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 laws
and regulations, including but not limited to, the Uniform Relocation Act and MA Department
of Environmental Protection demolition and asbestos disposal (if present) regulations.
2. All written materials, publications and correspondence issued by the Holyoke Housing
Authority to the tenants of Lyman Terrace relative to their relocation or displacement or
alternative housing options or the future of Lyman Terrace shall be provided in English and
Spanish.
3. Within thirty days of receipt of the Release of the Environmental Grant Certification from
HUD, the Holyoke Housing Authority shall distribute "Fair Housing for Individuals Receiving
Public or Housing Assistance" brochures produced by the MA Fair Housing Center to each
household/family tenant 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
professional legal assistance relative to their fair housing rights, the Holyoke Housing
Authority 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 the
Environmental Grant Certification from HUD. One meeting shall be during normal business
hours and one meeting shall be in the evening or a weekend day. Tenants shall be notified
3/28/2012 2
of the meeting in writing by the Holyoke Housing Authority and said notice shall be provided
in English and Spanish. Meeting notices shall be distributed at least seventy two hours in
advance and shall be posted at least seventy two hours in advance with the Holyoke City
Clerk, in the administrative offices of the Housing Authority, on the Housing Authority's
website, and in community spaces at Lyman Terrace. The Holyoke Housing Authority shall
ensure 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, if
needed. This recommendation is based upon public comments concerning the potential
limited availability of local affordable housing units due the number of foreclosures in the
Pioneer Valley and recent natural disasters 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 and post-demolition.
7. The Holyoke Housing Authority shall comply with the City of Holyoke Stormwater
Management Ordinance and the EPA Stormwater Pollution Prevention Plan (NPDES)
requirements to ensure that the 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
thirty days or more, the site or demolished portion thereof shall be graded, loamed and
seeded with a perennial seed mix to ensure adequate vegetative cover so as to prevent
erosion or dust prior to redevelopment. The Holyoke Housing Authority shall maintain the
site post-demolition including bi-monthly mowing to prevent overgrowth and woody
vegetation and trash/debris removal to ensure that the site does not become blighted prior to
redevelopment.
9. To abate potential temporary noise increases during the demolition so as to decrease
disturbance of the neighborhood, the RE strongly recommends daytime demolition work,
quieter construction equipment, and quieter demolition operations. (ie- no brick crushing
operations at site).
3/28/2012 3
FINDING: [5B.40(9)]
X* Finding of No Significant Impact
(The project will not result in a significant impact on the quality of the
human environment)
Finding of Significant Impact
(The project may significantly affect the quality of the human environment)
*The RE notes that the regulatory threshold for preparation of an Environmental Impact
Statement (EIS) based upon a Finding of Significant Impact is demolition of 2500
existing housing units. (24 CFR 58.37(a)(2)) This proposal is for demolition of 167
existing housing units- a factor 1115 of the regulatory threshold.
Preparer Signature:
~ Date:l!3m/9b(;).,
strator
Name/Title/Agency:
City of Holyoke Office for Community Development
RE Approving Official Sign
Name/Title/Agency: LI da cQuade, Administrator
City of Holyoke Office for Community Development
Statement of Purpose and Need for the Proposal: [40 CFR 150B.9(b)]
The Holyoke Housing Authority has determined that the Lyman Terrace Housing Complex is obsolete as
to its physical condition and that no reasonable program for modification is cost effective to return the
public housing complex to a long-term useful life. Factors considered in this determination include the
unit size, outdated unit and site utilities and infrastructure, non-accessibility, energy in-efficiencies,
construction materials prohibitive to rehab (masonry walls, concrete slabs/stairs), fire suppression, poor
ventilation, and poor site drainage. The Housing Authority asserts that the units do not meet housing
quality standards.
3/28/2012 4
Description of the Proposal: Include all contemplated actions which logically are
either geographically or functionally a composite part of the project, regardless of the
source of funding. [24 CFR 58.32, 40 CFR 1508.25]
The Holyoke Housing Authority proposes demolition of the housing complex and disposition of the
property.
Future uses of the property by the Holyoke Housing Authority or others have not been determined and
are not the subject of this Environmental Assessment. The RE notes that the Holyoke Housing Authority
is soliciting requests for proposals for the sale and redevelopment of Lyman Terrace. The RFP can be
viewed on line at www.holyokehousing.org.
Existing Conditions and Trends: Describe the existing conditions of the project area
and its surroundings, and trends likely to continue in the absence of the project. [24 CFR
58.40(a)]
Lyman Terrace is an existing occupied federalized public housing complex located in the downtown core
of Holyoke, Hampden County, MA. It was built in 1938 as the first public housing complex in Holyoke.
Lyman Terrace consists of 167 units and one HHA office in eighteen buildings on a 5.5 acre parcel
(Parcel 013-01-001). The buildings are brick, two story and aligned in terraced rows. The complex is
bounded by John, Front, and Lyman Streets. It is located in Census Tract 8117, Block Group 2.
Lyman Terrace is located in one of four Center City neighborhoods- the Prospect Heights/Downtown of
Holyoke. It is zoned Downtown Residential (DR) and is surrounded by various land uses. To the south is
a large concrete parking garage and abandoned blighted building (30 John Street). To the north on
Lyman Street, there are commercial and mixed uses including a banquet facility. Further west on along
Lyman Street are elderly housing complexes and a condo complex. To the east along Front Street, are
several vacant former mill buildings as well as social service offices. To the west, the property is bounded
by an alley between Lyman Terrace and rear of buildings along High Street.
Lyman Terrace is situated within walking distance of services and amenities including, governmental
offices (City Hall, Social Security Office), social services (DTA, DSS, WIC, VOC), medical services
(Holyoke Health Center), parks and recreational facilities (Pulaski Park, Heritage State Park, Children's
Museum), small retail stores (High Street), bars, restaurants, and a multi-modal transportation center
(Maple Street- PVTA).
According to the Baseline Economic Conditions & Market Characteristics Report for The Center City
Urban Renewal District. Holyoke MA October 2010, Center City had 10,720 persons in 3840 households
accounting for approximately 27% of the City's population. Housing estimates indicate a supply of 4400
units in Center City representing 26% of the City's supply. 560 units were vacant for a vacancy rate of
12.8%. Approximately 90% of the occupied housing units were rentals including a large supply of
subsidized housing.
According to the US Census Bureau- 2005-2009 American Community Survey, Census Tract 8117 has
1053 housing units- 890 of which are occupied and 163 which are vacant. 88.3% (786) of occupied
units are rental and 11.7% (104) of occupied units are owner occupied. The demolition of 167 units at
Lyman Terrace would reduce the number of occupied rental housing units in Census Tract 8117 by 21 %
(167/786). The median rent in Census Tract 8117 is $429.
3/28/2012
5
According to the 2011 FFIEC Census Report, the demographics for the Center City Census Tracts are as
follows:
Center City Households Tract Tract Hispanic Tract %
Census Population Minority % Population Hispanic % Below
Tracts Poverty
Line
8114 889 2534 85.67% 2109 83 % 49.49
8115 637 2169 93.13% 1929 89% 50.88
8116 1129 3560 90.59% 3089 87% 48.32
8117 1080 2346 72.46% 1588 68% 49.04
According to the US Census Bureau- 2000 Census, 89.7% of residents in Census Tract 8117 are low or
moderate 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 distressed
housing. The Holyoke Housing Authority has made several applications to the Hope VI Program and
most recently an application to the Choice Neighborhoods Program. Lyman Terrace was not selected for
either program by HUD and the Hope VI Program has since been eliminated in the federal budget. HUD
officials have visited Lyman Terrace on several occasions and one visit was highlighted in the HUD New
England News, Volume 2, Issue 5, September 2011 Newsletter.
The City of Holyoke has undertaken an urban renewal process for Center City. The proposed Urban
Renewal Plan is expected to be submitted to the Commonwealth of MA for approval in Spring 2012. In
development of the Urban Renewal Plan, the City in consultation with VHB, Inc. conducted a five month
visioning process which resulted in the 2009 Center City Vision Plan. Regarding Lyman Terrace, the
Center City Plan includes a Vision Plan Element to "Restore the Urban Neighborhoods" with the following
initiatives:
-Continue initiatives to stabilize current housing and introduce new housing options,
including moderately priced housing to complement the existing affordable housing in these areas.
-Support Holyoke Housing Authority's application for Hope VI funds to reconstruct the
Lyman Terrace complex and the development of housing within a 3 mile radius.
-Target for rehabilitation key vacant residential units that have valuable architectural
character.
3/28/2012
6
Statutory Checklist
[24CFR 58.5]
Record the determinations made regarding each listed statute, executive order or regulation. Provide appropriate
source documentation. Note reviews or consultations completed as well as any applicable permits or approvals
obtained 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 Documentation
Historic Preservation
MA SHPO - "Unlikely to affect significant historic"
~ 3 6 CFR 800L Source: MHC 12/28/2011
Floodplain Management
Zone C.
124 CFR 55, Executive Order 11988] Source: FEMA FirmeUe- Panel 4 of 8- 1979
Wetlands Protection
Site does not contain wetlands and is more than 100' from
[Executive Order 11990] nearest water body (Holyoke Canal System)
Source: DEP Wetlands Mapping
Coastal Zone Management Act
Inland MA
[Sections 307(c), (d)] Source: Google Map of MA
Sole Source Aquifers
Not in designated Sole Source Aquifer
[40 CFR 149] Source: www.epa.gov and Tighe & Bond, Phase I
Environmental Site Assessment- Page 2-2
Endangered Species Act
Not in Priority Habitat or Estimated Habitat
[50 CFR 402] Source: MA NHESP Mapping and Tighe & Bond, Phase I
Environmental Site Assessment- Page 2-2
Wild and Scenic Rivers Act
None designated in Holyoke.
[Sections 7(b), (c)] Source: www.rivers.gov
Air 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.gov
See Condition No.1 for air quality protection if asbestos
mitigation is needed.
Farmland Protection Policy Act
Urban core- no farmland on or adjacent to site.
[7 CFR 658] Source: Tighe & Bond, Phase I Environmental Site
Assessment- Page 2-1
Environmental Justice
Within an EJ designated area.
[Executive Order 12898] Source: MA Oliver Map and Tighe & Bond EJ Map
HUDE t I Sta d dDt t" nVlronmen a n ar s e ermlna Ion an dC r ompllance D ocumen tat" n 10
Noise 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 further
Chemicals or Gases
investigations at this time."
[24 CFR 58.5(i)(2)]
Source: Tighe & Bond, Phase I Environmental Site
Assessment- January 20,2012
Siting of HUDAssisted
No HUD assisted project is proposed for siting. Project is
Projects 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; existing
Accident Potential Zones
federalized housing project.
[24 CFR 51 D]
Source: Westover Joint Land Use Contours Map
2002 Land Noise Contours & Westfield Barnes Study Update
3/28/2012
7
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 appropriate
impact 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 Documentation
Conformance with 1 (1) This ERR is for demolition/disposition only and it is not within
Comprehensive Plans and Zoning the scope of this ERR to evaluate future use of the site. Future
use would undergo its own stringent environmental and land use
review which would ensure that it is compatible and feasible along
with adherence to land use and zoning ordinances.
(2) The HHA RFP requires that future use of the property be
consistent with the forthcoming Urban Renewal Plan.
Compatibility and Urban Impact 1 (1) This ERR is for demolition/disposition only and it is not within
the scope of this ERR to evaluate future use of the site. Future
use would undergo its own stringent environmental and land use
review which would ensure that it is compatible and feasible along
with adherence to land use and zoning ordinances.
(2) The HHA RFP requires that future use of the property be
consistent 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 2-2
Erosion 4 Requires compliance with Holyoke Erosion Control Ordinance
during and post demolition. See Conditions Nos.5, 8
Soil Suitability 1 Urban land.
Source: Tighe & Bond, Phase I Environmental Site Assessment-
Page 2-2
Hazards and Nuisances including 1 Project complies with 58.5(i)(2)(1) and HUD Technical Guidance
Site Safety Source: Tighe and Bond, Phase I Assessment January 20,2012
Page 4-2- No further investigations at this time.
Energy Consumption 1 Removal of substandard housing with outdated utilities
Source: Holyoke Housing Authority Justification
Noise - Contribution to 1 Demolition resulting in vacant lot will not increase community
Community Noise Levels noise level because there will be no land use therefore no noise
generated at the site. See Condition NO.9 for noise abatement
during demolition.
Air Quality
No SIP's identified in Holyoke. Project does not propose any new
Effects of Ambient Air Quality on 4 construction at this time.
Project and Contribution to Source: www.epa.gov
Community Pollution Levels
See Condition No.1 for air if asbestos is present
Environmental Design
(1) This ERR is for demolition/disposition only and it is not within
Visual Quality - Coherence, 1 the scope of this ERR to evaluate future use of the site. Future
Diversity, Compatible Use and
use would undergo its own stringent environmental and land use
Scale
review which would ensure that it is compatible and feasible along
with adherence to land use and zoning ordinances.
(2) The HHA RFP requires that future use of the property be
consistent with the forthcoming Urban Renewal Plan. (3)
3/28/2012
8
Compliance with Section 106 has been met (visual quality).
Source: MHC 12/28/2011
Socioeconomic Code Source or Documentation
Demographic Character Changes
2/ See below for description.
3
Displacement 4 Project will displace tenants in 167 units.
Mitigation: Uniform Relocation Act requirements. Relocation Plan
See Condition Nos. 1, 3, 4, 5
Employment and Income Patterns
1
65.4% of persons over 16 yo in Census Tract 8117 are not in the
workforce.
Source: US Census Bureau 2005-2009 American Community
Survey
Demographic Character Changes
The 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 may
argue that it results in gentrification of the urban core. There are no compliance standards, federal
legislation 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) that
100% of the 400 residents are low or moderate income (LIM) and (4) that all Lyman Terrace residents
relocate to areas outside of Census Tract 8117.
Existing/Pre-Demolition Post-Demolition
2011 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 FFIEC
2000 Data from US Census Bureau- 2000 Census
HUD Handbook 1390.2
Community Facilities
and Services
Educational Facilities*
Commercial Facilities
Health Care*
Social Services*
Solid Waste
Waste Water
3/28/2012
Code
1
3
1
1
4
1
Source or Documentation
Project does not increase need for educational facilities.
The loss of 167 units may result in a reduction in foot traffic to the
commercial corridor in downtown. HUD provides no compliance
standards for this category.
Source: Public comments regarding use of downtown
retail/commercial facilities
Project 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 DEP
Regulations to prevent adverse effects.
Site is serviced by municipal waste water.
Source: Tighe & Bond, Phase I Environmental Site Assessment-
9
Page 2-1
Storm Water 4 Project must comply with City of Holyoke Stormwater Ordinance
and 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 2-2
Public 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 it
burden existing transportation resources.
*The RE recognizes that the tenants' access to these services may be impacted by this project. However this ERR is
reviewing the impacts of the proposal on each of the community facilities. For example if 167 units/400 people were
moving into an area, these services, if already overburdened, may be further impacted.
Natural Features Source or Documentation
Water Resources 1 None within 100' of site.
Sources: Tighe & Bond Aerial Photo Parcel Map
DEP Priority Resource MaQ
Surface Water 1 None within 100' of site.
Sources: Tighe & Bond Aerial Photo Parcel Map
DEP 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 Site
Assessment- Page 2-1
Vegetation and Wildlife 1 Urban well-developed site
Source: Tighe & Bond, Phase I Environmental Site
Assessment- Page 2-2
Other Factors Source or Documentation
Flood 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 MA
Coastal 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 Zone
Clear Zone Disclosure Source: Westover Joint Land Use Contours Map
[58.6(d)]
2002 Land Noise Contours
Other Factors
3/28/2012
10
Summary of Findings and Conclusions
ALTERNATIVES TO THE PROPOSED ACTION
Alternatives and Project Modifications Considered [24 CFR 58.40(e), Ref. 40 CFR 1508.9]
(Identify other reasonable courses of action that were considered and not selected, such as other sites, design
modifications, or other uses of the subject site. Describe the benefits and adverse impacts to the human environment
of each alternative and the reasons for rejecting it.)
Lyman Terrace has been identified in previous applications for HUD assistance as severely distressed
housing. The Holyoke Housing Authority has made several applications to the Hope VI Program and
most recently an application to the Choice Neighborhoods Program. Lyman Terrace was not been
selected for either program by HUD and the Hope VI Program has since been eliminated in the federal
budget. HUD officials have visited Lyman Terrace on several occasions and one visit was highlighted in
the HUD New England News, Volume 2, Issue 5, September 2011 Newsletter.
No Action Alternative [24 CFR 58.40(e)]
(Discuss the benefits and adverse impacts to the human environment of not implementing the preferred alternative).
A "no action alternative" would avoid demolition and disposition to preserve Lyman Terrace in its current
sub-standard state. Tenants would remain in severely distressed housing. However, tenants would not
be displaced and would not be subject to the potentially adverse stresses associated with relocation
(housing search, unfamiliar surroundings, separation from family/friends/services, etc.).
Mitigation Measures Recommended [24 CFR 58.40(d), 40 CFR 1508.20]
(Recommend feasible ways in which the proposal or its external factors should be modified in order to minimize
adverse environmental impacts and restore or enhance environmental quality.)
See Conditions for Approval.
Additional Studies Performed
(Attach studies or summaries)
See attached Response to Public Comments for additional information and ERR file.
List of Sources, Agencies and Persons Consulted [40 CFR 1508.9(b)]
In addition to the sources referenced herein and those provided in the ERR, the following sources were
consulted:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
3/28/2012
US Census Bureau- 2000 Census
US Census Bureau- 2005-2009 American Community Survey
2011 FFIEC Census Report Summary Census- Summary Census Income and Census
Population Information MSAMD: 44140 Springfield MA (Federal Financial Institutions
Examination Council)
Holyoke's Center City Vision Plan Prepared by VHB on behalf of the City of Holyoke and the
Holyoke Redevelopment Authority. August 2009.
HUD New England News Volume 2 Issue 5 (September 2011) Retrieved March 28, 2012
from http://portal.hud.gov/hudportal/documents/huddoc?id=20 10-08-03. pdf 0
Request for Proposals Retrieved multiple dates from www.holyokehousing.org
Baseline Economic Conditions and Market Characteristics- The Center City Urban Renewal
District Holyoke, Massachusetts Prepared by RKG Associates, Inc. October 2010
The Environmental Review Process Retrieved multiple dates from
http://www.nls.gov/offices/cpd/affordablehousing/training/web/crosscutting/environmental/revi
ewstage1.cfm
24 CFR Parts 51 & 58
Environmental Assessment Guide for Housing Projects Retrieved multiple dates from
http://www.hud.gov/offices/adm/hudclips/handbooks/cpdh/1390.2/index.cfm
11