Environmental Assessment

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1 Environmental Assessment Conversion of Two Small Parcels of Wald Park with Replacement by Recreational Area at the Former Altadena Valley Country Club A conversion of land protected under Section 6(f)3 of the Land and Water Conservation Fund Act, Public Law This Environmental Assessment is being submitted concurrently with an application to the National Parks Service for Amendment to the LWCF Project at Wald Park, which is included in the Appendix to this document. October 1, 2017 Note: Appendix to this assessment includes the Figures in the narrative. An electronic version is also available in which the images are more easily viewed. Find the electronic version on For Information Contact: Jeffrey Downes, City Manager jdownes@vhal.org Phone (205) Fax (205) Project Sponsor: City of Vestavia Hills, Alabama Submitted to: Alabama Department of Economic and Community Affairs For: National Park Service Southeast Regional Office 100 Alabama Street, SW Atlanta, GA 30303

2 THIS PAGE RESERVED FOR UPDATES December This Environmental Assessment for public review is preliminary, and updates will be made as more information is available. Missing from this document are the formal appraisal values and letters of concurrence from various regulatory agencies. Any additions or significant changes to this document will be listed on this page. If you would like to be alerted to changes to this document, please administration@vhal.org or call Melissa Hipp at (205) September This Environmental Assessment has been updated as follows: Inclusion of the required appraisal meeting the Uniform Appraisal Standards for Federal Land Acquisition (UASFLA), as approved by the Alabama Department of Transportation (ALDOT). Inclusion of archaeological survey recommending a finding of no properties to the Alabama Historical Commission, AHC concurrence. Inclusion of other letters of concurrence and comments. Updated descriptions for the planned uses of the Wald Park parcels to be converted. Noted intention to bank the appraised value of the replacement property (Altadena Valley Country Club) which is in excess of the value required for the swap. The banked value plus the value of other property the City anticipates to acquire (adjacent to Wald Park) may be applied towards a future request for conversion of another parcel within the existing Wald Park Section 6(f) boundary. Supplementation to the Appendix to add a Future Conversions section describing the City s intent to bank land swap value and anticipate additional conversions. Updated description of Altadena Valley Country Club use to reflect feedback received during the Community Spaces Plan public meetings held July and August 2017.

3 CONVERSION OF TWO SMALL PARCELS OF WALD PARK WITH REPLACEMENT BY RECREATIONAL AREA AT THE FORMER ALTADENA COUNTRY CLUB 2.52 Acre Conversion (2 Parcels) of Wald Park Subject 1 (School Expansion) adj. to 1965 Merryvale Road, Vestavia Hills, AL Subject 2 (Public Works) 1280 Montgomery Highway, Vestavia Hills, AL Jefferson County, Alabama Proposed Replacement Parcel Former Altadena Valley Country Club (2651 Alta Vista Drive, Birmingham, AL 35243) Vestavia Hills, Shelby County, Alabama ENVIRONMENTAL ASSESSMENT For Public Review and Comment Prepared November 2016 / Updated September 2017 In order to fulfill the requirements of the Land and Water Conservation Fund Program of the National Park Service A project of the City of Vestavia Hills In Partnership with the Alabama Department of Economic and Community Affairs Ashley C. Curry Mayor Jeffrey Downes City Manager

4 Table of Contents SUMMARY... 1 INTRODUCTION... 6 Purpose, Need and Background... 7 DESCRIPTION OF ALTERNATIVES No Action Proposed Alternative Other Alternatives Affected Environment Wald Park... Former Altadena Valley Country Club... Environmental Impact Wald Park... Former Altadena Valley Country Club... Coordination and Consultation Appendix The Land and Water Conservation Fund (LWCF), Stateside Assistance grant program, provides funds to states, and through states to local agencies, for the acquisition and development of outdoor recreation resources. Lands that have received funding through LWCF are protected by section 6(f)3 of the Act unless a conversion is approved by the Secretary of the Interior as delegated to the National Park Service.

5 SUMMARY The CITY OF VESTAVIA HILLS proposes to remove from federal protection two portions of WALD PARK in order to align its Section 6f boundaries with the intended uses of the property. Conversion Subject 1 (School Expansion) is a small polygon adjacent to the school owned property which the City would like to convey to the school for expansion. Conversion Subject 2 (Public Works) is a main thoroughfare frontage parcel which is currently occupied by the municipal public works facility and which the City would like to redevelop into revenue generating commercial use. The CITY OF VESTAVIA HILLS proposes to mitigate this impact with the dedication and development of the RECREATIONAL AREA at the FORMER ALTADENA VALLEY COUNTRY CLUB. WALD PARK is located along US 31 in Vestavia Hills, Jefferson County, Alabama. This acre park property was placed under Section 6f protection in 1979, and although it had been intended at that time to disinclude the public works facility site (Subject 2), the parcel was inadvertently included on the Section 6f boundary map. Wald Park continues to be a recreational area, and it is located at 1973 Merryvale Road, Vestavia Hills, AL Conversion Subject 1 (School Expansion) is adjacent to Vestavia Hills Elementary West, which is addressed 1965 Merryvale Road, Vestavia Hills, AL Conversion Subject 2 (Public Works) is separately addressed as 1280 Montgomery Highway, Vestavia Hills, AL (See Figure 1) Note: The City of Vestavia Hills has recently taken the first step towards initiating its Community Spaces Plan that has been developed in response to recent assessments of recreational needs in Vestavia Hills. Wald Park is the centerpiece of this plan, which impacts recreational spaces throughout the city. The City is currently studying, through consultation with a program manager, the feasibility of various options of the plan, which is found at Under consideration is construction of a building near the area of the existing Exchange Field and its parking lot. This building may be primarily a support facility for the pool, or it may include other indoor uses which may trigger need for conversion. Also under consideration is whether to convert a small parcel adjacent to Subject 2 (Public Works), as this would expand the available space for commercial use. Since the time the preliminary EA was prepared, the first potential buyer ( Freddy s ) of the Public Works site decided to locate elsewhere. Other potential buyers have expressed interest, with at least one requesting if the lot can be expanded by this additional parcel. To offset either possibility, the City intends to bank for future conversions the excess value of the proposed Altadena Valley Country Club swap. The City also anticipates acquisition of property which is adjacent to Wald Park. According to the Community Spaces Plan, this newly acquired property would be for outdoor recreational use and/or its support. Page 1

6 Figure 1 Wald Park Site Location Map Page 2

7 Beginning 2012, the City recognized the need to strategically redevelop the US 31 corridor. It was determined that the frontage parcel at 1280 Montgomery Highway, currently used as the Public Works facility, has potential to be a revenue generating property if converted to commercial use. When the opportunity to sell the property presented in 2016, it was discovered that the parcel was within the 1979 Section 6f boundary map, thus triggering the need for a conversion in order for the City to sell the property. Concurrently with the timing of the offer on the Public Works site in 2016, the Vestavia Hills Board of Education sought to obtain additional property to allow for an expansion of its Vestavia Hills West Elementary building. It was determined that this also would require a conversion of the property which the City plans to convey to the Board of Education. The conversion process of the Land and Water Conservation Fund (LWCF) program requires that an equal property be used to replace any property that is protected under LWCF Act Section 6f(3). The City is proposing to place under Section 6f(3) a portion of the recently purchased property of the former Altadena Valley Country Club. Section 6f(3) protection is consistent with the intended recreational use for this property. As the future park is yet to be named, in this document it will be referenced as RECREATIONAL AREA at the FORMER ALTADENA VALLEY COUNTRY CLUB, hereinafter referenced as AVCC. RECREATIONAL AREA at the FORMER ALTADENA VALLEY COUNTRY CLUB is located off Acton Road in Jefferson and Shelby Counties. The City partnered with a private developer such that part of the former country club was donated to the City in return for annexation of the portion retained by the developer. To provide for a new entrance to the park, the City also purchased two adjacent properties. While the new park address is yet to be determined, the old Altadena Valley Country Club was addressed as 2651 Alta Vista Drive, Birmingham, AL (See Figure 2) Page 3

8 Figure 2AVCC Site Location Map In addition to the proposed action, the CITY OF VESTAVIA HILLS also evaluated the following alternatives: a) Subject 1 (School Expansion) No Action While the onus is on the Vestavia Hills Board of Education to adjust construction plans should the City not convey the proposed property, the Page 4

9 City has determined it to be of greater public benefit for the property to be used for the school rather than retain it as landscape buffer. Since December 2016 when the preliminary EA was prepared, the Vestavia Hills Board of Education did elect to construct its immediate expansion within its own existing property. However, the City wishes to proceed with the conversion to allow for similar future use. b) Subject 2 (Public Works) No Action The No Action alternative of continuing to use the location for a public works facility was considered through the planning process which concluded such is not the highest and best use of the property and thus prompted the marketing of the frontage property for commercial use. c) Subject 2 (Public Works) No Action/Recreational Use A No Action alternative of not converting the property but instead using it for recreational space has not been favored due to the economic development potential for the frontage location along US 31, particularly in light of a viable offer. Based upon the effects of the alternatives, the CITY OF VESTAVIA HILLS is requesting that the Alabama Department of Economic and Community Affairs (ADECA) forward a recommendation to the National Park Service (NPS) to approve the proposed conversion and replacement. ADECA administers the Land and Water Conservation Fund program for Alabama; the Director of ADECA is the State Liaison Officer (SLO) for the National Parks Service. Page 5

10 INTRODUCTION In 1979, CITY OF VESTAVIA HILLS received a LWCF grant for the improvement of parks and recreational facilities at WALD PARK, thereby protecting it for public outdoor recreation under section 6(f)3 of the LWCF Act. Section 6(f)3 requires that protected parkland that is converted to a use other than outdoor recreation be replaced with property that is of at least equal fair market value and equivalent recreation utility as the property that was converted. The replacement property must constitute a viable recreation unit, or be acquired as an addition to an existing recreation unit. Development of the replacement property may be required to ensure that a level of recreation utility is achieved similar to what was lost at the converted site. The currently protected portion of WALD PARK is depicted in Figure 3, which also shows the outline of the proposed conversion. Figure 4 depicts the boundary of WALD PARK that will remain protected by 6(f)3 if the conversion is approved. Figure 3 Current 6f boundary of Wald Park with proposed conversion overlay Page 6

11 Figure 4 New Section 6f boundary of Wald Park if conversions accepted Purpose, Need and Background The purpose of this conversion is to remove from federal protection two portions of WALD PARK in order to align its Section 6f boundaries with the intended uses of the property. Conversion Subject 1 (School Expansion) is a small polygon adjacent to the school owned property which the City would like to convey to the school for expansion. This action is prompted by the need for increased capacity at the impacted school, Vestavia Hills Elementary West, which has grown just as has the need for increased capacity system-wide. Conveyance of the proposed school expansion property will allow for a larger cafeteria and additional physical education space. The population of the City of Vestavia Hills has grown to 34,000 from 15,722 since 1980, and continued population growth is anticipated as new residential areas are being developed. Conversion Subject 2 (Public Works) is a main thoroughfare frontage parcel which is currently occupied by the municipal public works facility and which the City would like to redevelop into revenue generating commercial use. This Page 7

12 action is needed because sustainment of the City s financial strength and ability to competitively provide quality of life for its residents and businesses requires growth of revenues above its current figures. Such growth is needed not only to sustain the existing level of economic health, but also to support future quality of life investments such as the $50 million Community Spaces Plan ( The impact commercial use such as a restaurant can make has been seen first-hand in Vestavia Hills as the highproducing Vestavia Hills Chick-fil-A has raised the City s revenue by approximately $150,000 since its opening in July Actual General Fund Revenue Per Capita Municipality 2015 Actual General Fund Revenue* Population General Fund Revenue Per Capita % Difference From Vestavia Hills Vestavia Hills $ 35,259,597 34,174 $ 1, Homewood $ 40,504,448 25,708 $ 1, % Mt Brook $ 35,110,391 20,691 $ 1, % Birmingham $ 397,859, ,461 $ 1, % Hoover $ 109,927,118 84,848 $ 1, % Bessemer $ 51,614,611 26,730 $ 1, % * Source: FY 15 Audited Financial Statement except Bessemer- FY 14 Audit Report Table 1 General Fund Revenue Per Capita, from Vestavia Hills City Manager Jeff Downes' FY 2017 Annual Budget Message to the City Council. While the City is proud of its ability to operate efficiently and provide excellent quality of life for its residents, to remain competitive it will need to increase its revenue per capita. The CITY OF VESTAVIA HILLS proposes to convert the Subject 1 (School Expansion) 0.25 acre and Subject 2 (Public Works) 2.27 acre portions of Wald Park (2.52 total converted acres proposed, no recreational use lost), and replace them with acres of RECREATIONAL AREA at the FORMER ALTADENA VALLEY COUNTRY CLUB, hereinafter referred to as AVCC. The concept for development at AVCC includes the features listed below, and land has been purchased and design completed for a western entrance road to the park. At the time of this environmental assessment, public meetings were being held to determine more specifically what would be included in the park. The program manager will make budget recommendations for the park within the Community Spaces Plan, and the City Council will begin the decision making process for the actual scope and timeline in fall If plans for the park are approved, it is reasonable to anticipate the passive recreational features of the park may be substantially completed before Note: LWCF Manual E3d - If full development of the replacement site(s) will be delayed beyond three years from the date of conversion approval, the conversion proposal shall explain why this is necessary (see Chapter 3.B.7). Page 8

13 canoe launch to the Cahaba River dog park play structure (type to be determined) passive play ground play lawn disc golf picnic area retention ponds (with potential use as fishing ponds) trail/sidewalk system 1.5 mi ample parking for both the active and the passive recreation areas possible future phase to include baseball diamonds and rectangle athletic courts The site location for AVCC is shown in Figure 2 above. Figure 5 below depicts the proposed Section 6f boundary of AVCC in color; this boundary represents the entire boundary of the park. Figure 6 depicts the proposed site development plan for AVCC. This Environmental Assessment is required to help the National Park Service evaluate the environmental consequences of the proposed action on the human environment and allow the affected public to understand the context for the proposed action. Figure 5 AVCC Proposed Section 6f Map Page 9

14 Figure 6 Original concept for new recreational area at the former Altadena Valley Country Club Page 10

15 DESCRIPTION OF ALTERNATIVES No Action Conversion Subject 1 (School Expansion) In the No Action alternative of not conveying the requested parcel to the schools, i.e. retaining it within the Section 6f boundary, it is likely to continue to be landscaping buffer between the school and recreational area. (It is unlikely that conveying the property for school expansion would result in deepening the landscape buffer within the Section 6f boundary as the parcel currently abuts a parking area.) Since December 2016 when the preliminary EA was prepared, the school determined to construct its immediate expansion within its existing property. The additional property would be used for a second phase of expansion as school enrollment continues to grow. Conversion Subject 2 (Public Works) In the No Action alternative of continuing to use the subject parcel for the municipal fleet maintenance and public works facilities, the anticipated costs and benefits are as follows: Unrealized economic development opportunity of estimated $1.2 million sale of the property, $3 million in new construction, and $3 million annually in sales and use and property tax revenues. Continued lack of southbound drive-through restaurants on US 31. There are no southbound drive-through restaurants in the 5+ miles from departure at downtown Homewood until reaching the Vestavia Hills Zaxby s past Wald Park. A drive-through restaurant at this location would not only serve southbound travelers on US 31, but it would also be convenient to users of Wald Park and to students, library patrons, or others who might cross from the Library using the future pedestrian bridge across US 31. The Section 6f map shown in Figure 3 shows existing conditions. Proposed Alternative The Proposed Alternative is to convert two subject parcels of Wald Park and replace them with a single park located at the former Altadena Valley Country Club. The AVCC is located a little over 5 miles from Wald Park, which is an minute driving distance. The AVCC is within a 10 minute drive for 90% of the Vestavia Hills population. Page 11

16 Figure 7: Locations of existing and potential recreational spaces in Vestavia Hills Demographics Demographics for the Vestavia Hills population are shown in Table 2 below. Wald Park also has many regional visitors for athletic events and for events held at the Civic Center. US Census Bureau Quick Facts Census, April 1, 2010 Data Total Population 34,033 Age and Sex Persons under 5 years, percent 6.4 Persons under 18 years, percent 25.3 Persons 65 years and over, percent 15.3 Female, percent 52.4 Male, percent 47.6 Race and Hispanic Origin White alone (not Hispanic or Latino) 88.9% Black or African American alone 3.8% American Indian or Alaska Native alone 0.2% Page 12

17 Asian alone 3.8% Hispanic or Latino 2.5% Two or More Races 1.0% Households 13,637 Geography Population per square mile Land area in square miles (2010) Table 2: Demographics of population served by Wald Park and the proposed park at AVCC Subject 1 (School Expansion): Conversion of the 0.25 acre parcel will allow for the Vestavia Hills Board of Education to add to Vestavia Hills Elementary West and expand its (school access only) outdoor recreational/physical education area that would be located below the building extension. See the image below for the existing building and the school playground. Figure 8 Existing conditions at Conversion Subject 1 (shown behind playground equipment) Subject 2 (Public Works): Conversion of the 2.27 acre parcel to commercial use would yield construction and annual revenue which could be reinvested into the Vestavia Hills parks and recreation system and (if purchased by a fast food restaurant)* fill a gap in drive-through restaurant availability on US 31 southbound. Furthermore, the conversion would place a significantly larger amount of property with significantly greater recreational opportunities under Section 6f protection. Page 13

18 *While previous interest in the Public Works site has been from the fast food industry, it is unknown what commercial use will ultimately occupy the location. Description of WALD PARK No recreation opportunities will be lost through this conversion. Wald Park consists of outdoor recreation areas within the Section 6f boundary and other uses (civic center and gym, school, chamber of commerce) that are outside the protected boundary. The Section 6f protected property known as Wald Park is made up of acres including the 2.27 acres used for the public works and fleet maintenance facilities and an 0.25 acre area the school would like to acquire. There are no recreational uses currently on either of these conversion subject parcels, and the remainder of the Section 6f area of Wald Park includes a pool, tennis courts, playgrounds, soft ball and multipurpose playing fields, a track, a pavilion, and picnic areas. These can be seen in Figure 3. Note: If the City proceeds with application for additional conversion of property adjacent to Subject 2, this also will result in no loss of recreation opportunities. That adjacent property is currently unused wooded buffer, and it is estimated to be 0.3 acres. What is the acreage lost? What is left? To be removed from the Section 6f boundary are a total of 2.52 acres. The remaining acreage is (Alternately, the remaining acreage would be 20 if supplemental conversion is required for the Public Works site.) What is fair market value of what s lost? The total fair market value of the two properties per Uniform Standards for Federal Land Acquisition (USFLA) has been determined as follows: Conversion Subject 1 (School Expansion) The 0.25 acre parcel proposed to be conveyed to the school system as a donation has been appraised at $26,000. Conversion Subject 2 (Public Works) - The 2.28 acre parcel at 1280 Montgomery Highway, Vestavia Hills, AL has been appraised at $1,350,000. What is the recreation utility of what s lost? No recreational utility will be lost by converting these parcels. Subject 1 has no equipment or play/recreational space use, i.e. it is landscape buffer between the school and the recreational areas. Subject 2 has been occupied by the municipal public works and fleet maintenance facilities since before the original Section 6f boundary was drawn. Operations at the existing Parks and Recreation maintenance facility (outside the Section 6f boundary) will be expanded to include public works, and the fleet maintenance will be relocated offsite. Page 14

19 What is the population served by Wald Park? Note that the parcel proposed for conversion currently serves no recreational use, and therefore there will be no negative impact to the availability of recreational opportunities to the users of the park. Wald Park is situated within a ten minute drive of ninety percent of the Vestavia Hills population, which is 34,174 (July 2015 population estimates, US Census). Wald Park is proximal to two elementary schools and the library. In the near future, a pedestrian bridge (to be located just north of the parcel proposed for conversion) will connect the library and school on the northbound side of US31 to Wald Park and the school on the southbound side. A recent study found that Wald Park s athletic fields are typically fully booked (except during periods of maintenance and inclement weather), predominantly with youth teams. Regional visitors often utilize the pavilion, picnic areas, and event spaces. See Table 2 for Vestavia Hills demographics. Describe any public involvement in the proposal to date. Upon the expiration of the original restriction of use as outlined in the deed when the property was conveyed to the City by the Wald family, it was assumed the property was unrestricted for the City to repurpose as deemed in the best public interest. The Vestavia Hills Board of Education has led public discussion in the last couple of years about expansion options through its system and most recently at Vestavia Hills Elementary West (adjacent to Wald Park). Although (due to the delay from the conversion requirement) the BOE determined to construct its immediate expansion within its own existing property, the City still anticipates conveyance of Subject Parcel 1 to the BOE for future school expansion. The public discussion of the disposition of the public works site has been through two planning exercises in 2012, the Vestavia Hills Vision Plan facilitated by Market Street Services, Inc. and the US 31 Redevelopment Plan led by the Regional Planning Commission of Greater Birmingham. An outcome of those exercises was that selected parcels of US 31 frontage including the public works site should be rezoned for commercial use. Thus far, the City has been successful in selling its former municipal complex site to Chick-fil-A restaurant and the former library site to America s First bank. These and other recent economic development projects have contributed to the City s ability to add to its public safety force and proceed with projects such as a pilot sidewalk program and recreational improvements at Sicard Hollow Athletic Complex in Liberty Park and Meadowlawn Park green space in Cahaba Heights. Current public conversations about recreational space planning (Community Space Plan) disinclude the Public Works site. A location map of the proposed conversion site is found in Figure 1 (page 2) A map of the existing 6(f) boundary with an overlay of the proposed conversion area. and the proposed final Section 6f map are shown in Figures 3 and 4 (pages 6-7). Note: The new Section 6f boundary as shown in Figure 4 may need modified to reflect supplemental conversion adjacent to Site 2. An Alternate proposed Section 6f map is included in the appendix to reflect Site 2 as a total of ±2.6 acres and the protected boundary of Wald Park as 20 acres. Page 15

20 Description of RECREATIONAL AREA at the FORMER ALTADENA VALLEY COUNTRY CLUB (AVCC) A description of the replacement park including a description of the planned development, new recreation opportunities to be provided, and a timetable for completion. What is the acreage gained? Approximately acres of new park property will be placed under Section 6f protection through this conversion. What is the fair market value of the acreage gained? The AVCC property is made up of three parcels, the former Altadena Valley Country Club ±77 acre property donated to the City, plus additional property the City purchased so that it could create a new western access road to the future park. (That additional property purchase included 1.2 acres from International Park Meisler-Keith LLC and from Jefferson County). The property was appraised in 2017 according to the standards of the Uniform Standards for Federal Land Acquisition (USFLA), and the value was determined to be $1,500,000. As this amount exceeds the market value of the conversion properties in this proposal, the City intends to bank the values against future conversions. See Appendix VI for further description. As the replacement property for the proposed conversion of the parcel at Wald Park, the AVCC property is owned by the City of Vestavia Hills and the park to be constructed there will be operated by the City. What is the new recreation utility? The AVCC will offer a wide variety of outdoor recreation opportunities: canoe launch to the Cahaba River dog park play structure (type to be determined) passive play ground play lawn disc golf picnic area trail/sidewalk system1.5 mi retention ponds (with potential for use as fishing ponds) ample parking for both the active and the passive recreation areas possible future phase to include baseball diamonds and rectangle athletic courts If plans for the park are approved, it is reasonable to anticipate the passive recreational features of the park may be substantially completed before The western entrance road to the park design has been completed and is awaiting decision by the City Council whether to proceed with construction. Regardless, road access to the property exists now and the City will ensure sufficient access as the park is developed. Page 16

21 Discuss any public involvement in determining the proposed park design. How does this fit in with your park master plan? How does this comply with SCORP? The Vestavia Hills Parks and Recreation Board continually engages in planning activities and regularly seeks public input. In 2015, the City hired Brailsford and Dunlavey to conduct a study of the recreational facilities of the City of Vestavia Hills. From that study the current Vestavia Hills Parks and Recreation Master Plan was developed. The City began to explore the acquisition of the AVCC property in 2014, and use of the AVCC was discussed in public meetings about the master plan. A conceptual drawing for the AVCC was presented which was responsive to the needs expressed in the master plan in a number of ways. That conceptual drawing included several athletic fields, but whether to keep the park entirely passive or to limit the number of athletic fields was a subject of debate during the Community Spaces Plan public meetings. Presently the City plans to initially develop the park with passive recreational features, with athletic fields to be added later as it is better determined how many and what type of athletic fields should be located there. The location of the park is within a 10 minute drive for the majority of the Vestavia Hills population. By the addition of up to four rectangle fields (8 youth size), it addresses the identified deficit of rectangle field hours in relation to the demand. The walking paths and natural areas address the top three expressed needs for improvement in our recreational programs, plus others that rated highly: walking paths 46%, natural areas 33%, nature trails 27%, dog park 23%, playgrounds 20%. The AVCC park addresses the current SCORP in the following ways: 1. Includes several components which support recreational activities in which the population of Region 3 participate in on a weekly basis: walking for pleasure/jogging, nature photography, and potentially freshwater bank fishing (also soccer if athletic fields are included in future construction phases). (Alabama SCORP, 2013, pg. 43) 2. It includes several components which address top ranked activities in the #1 stated outdoor recreational needs for SCORP Region 3 (Alabama SCORP, 2013, pg. 90): Parks, 1 Walking trails, 2 Playgrounds, 3 Nature trails/preserves, 9 (If/when athletic fields added) i. Soccer fields, 13 ii. Softball fields, 7; Baseball fields, 6 3. Protection of the AVCC park property is consistent with the 2013 Alabama SCORP Strategy 1 in that it would protect greenspace and natural water features of the Cahaba River (pg.106). Page 17 The location map and proposed Section 6f map for the AVCC replacement site are found in Figures 2 and 5, and the new recreational opportunities are depicted in Figure 6.

22 The site is a former private golf course that is bounded on the north by future residential development and on the south by a conservation easement that includes An unnamed tributary of the Cahaba River. The new recreational area will include a canoe launch to provide public access to the stream. A super sewer subsurface easement runs along the north of the protected boundary, as does an abandoned sewer line (but the easement still exists). The sewer easement is deep beneath the ground surface and is not a barrier to development. To alleviate traffic concerns for the residents living near the park, a western entrance has been designed. The existing entrance is considered sufficient for the park if developed for passive recreational use only. Should athletic fields be constructed, the City is prepared to construct the western entrance, in which case the eastern entrance would be closed to vehicular traffic. The proposed Section 6f map depicts the park as ultimately having the western entrance. Other Alternatives 36 CFR Ch1, Part 59 requires that all practical alternatives to the conversion have been considered. Discuss why you couldn t avoid park impacts here. The CITY OF VESTAVIA HILLS proposes to remove federal protection two portions of WALD PARK in order to align its Section 6f boundaries with the intended uses of the property. There are no recreational facilities on either of the proposed conversion sites, so what is lost is the potential for future recreational activity at those locations. Due to the proximity of the school building, it is unlikely that the City would construct or install recreational equipment at Subject 1 (School Expansion). Subject 2 (Public Works) has been protected through a technical error, as it was a public works facility site at the time of application and has remained so until the City s recent efforts to repurpose the property for economic development. Page 18

23 Affected Environment The National Park Service requires assessment of LWCF properties using its Environmental Screening Form (ESF) to determine the resources on site likely to be negatively impacted and describe them as they currently exist. The Environmental Screening Forms for Wald Park and the proposed replacement property (AVCC) were reviewed by Christopher Brady, PE, City Engineer for the City of Vestavia Hills, Alabama. Impacts to these resources will be described in the next section, Environmental Impact. The outcome of review of this Environmental Assessment will be either a Finding of No Significant Impact (FONSI) statement or a requirement for further study of the environmental impact. At this time it is anticipated there will be no significant impacts for this project. It is worth noting that the park is being designed in a way as to offset runoff from the adjacent development, and the City has interest in preserving the quality of the stream not only for its value to the environment but also for recreational use. Shown below are the checklists from the ESFs found in the Appendix of this document. Letters of concurrence/comments from the following are included in this appendix: ALDOT determination of compliance with UASFLA appraisal standards AHC concurrence with UA recommendation for finding of no properties (AVCC), AHC US Department of the Interior comments (AVCC), 2017-TA-0123 US Army Corps of Engineers Preliminary Jurisdictional Determination (AVCC), SAM APW Any comments from the EPA and ADEM would follow review of this Environmental Assessment and/or application for a Section 404 permit. WALD PARK A. ENVIRONMENTAL RESOURCES Indicate potential for adverse impacts. Use a separate sheet to clarify responses per instructions for Part A on page Geological resources: soils, bedrock, slopes, streambeds, landforms, etc. 2. Air quality 3. Sound (noise impacts) 4. Water quality/quantity 5. Stream flow characteristics 6. Marine/estuarine 7. Floodplains/wetlands Not Applicable- Resource does not exist No/Negligible Impacts- Exists but no or negligible impacts Minor Impacts Impacts Exceed Minor EA/EIS required More Data Needed to Determine Degree of Impact EA/EIS required Page 19

24 8. Land use/ownership patterns; property values; community livability positive impact 9. Circulation, transportation 10. Plant/animal/fish species of special concern and habitat; state/ federal listed or proposed for listing 11. Unique ecosystems, such as biosphere reserves, World Heritage sites, old growth forests, etc. 12. Unique or important wildlife/ wildlife habitat 13. Unique or important fish/habitat 14. Introduce or promote invasive species (plant or animal) 15. Recreation resources, land, parks, open space, conservation areas, rec. trails, facilities, services, opportunities, public access, etc. Most conversions exceed minor impacts. See Step 3.B 16. Accessibility for populations with disabilities 17. Overall aesthetics, special characteristics/features 18. Historical/cultural resources, including landscapes, ethnographic, archeological, structures, etc. Attach SHPO/THPO determination. 19. Socioeconomics, including employment, occupation, income changes, tax base, infrastructure positive impact 20. Minority and low-income populations 21. Energy resources (geothermal, fossil fuels, etc.) 22. Other agency or tribal land use plans or policies 23. Land/structures with history of contamination/hazardous materials even if remediated 24. Other important environmental resources to address. RECREATIONAL AREA at AVCC A. ENVIRONMENTAL RESOURCES Indicate potential for adverse impacts. Use a separate sheet to clarify responses per instructions for Part A on page Geological resources: soils, bedrock, slopes, streambeds, landforms, etc. 2. Air quality Not Applicable- Resource does not exist No/Negligible Impacts- Exists but no or negligible impacts Minor Impacts Impacts Exceed Minor EA/EIS required More Data Needed to Determine Degree of Impact EA/EIS required 3. Sound (noise impacts) 4. Water quality/quantity Page 20

25 5. Stream flow characteristics 6. Marine/estuarine 7. Floodplains/wetlands 8. Land use/ownership patterns; property values; community livability 9. Circulation, transportation 10. Plant/animal/fish species of special concern and habitat; state/ federal listed or proposed for listing 11. Unique ecosystems, such as biosphere reserves, World Heritage sites, old growth forests, etc. 12. Unique or important wildlife/ wildlife habitat 13. Unique or important fish/habitat 14. Introduce or promote invasive species (plant or animal) 15. Recreation resources, land, parks, open space, conservation areas, rec. trails, facilities, services, opportunities, public access, etc. Most conversions exceed minor impacts. See Step 3.B 16. Accessibility for populations with disabilities 17. Overall aesthetics, special characteristics/features 18. Historical/cultural resources, including landscapes, ethnographic, archeological, structures, etc. Attach SHPO/THPO determination. 19. Socioeconomics, including employment, occupation, income changes, tax base, infrastructure 20. Minority and low-income populations 21. Energy resources (geothermal, fossil fuels, etc.) 22. Other agency or tribal land use plans or policies 23. Land/structures with history of contamination/hazardous materials even if remediated 24. Other important environmental resources to address. Page 21

26 Environmental Impact As stated previously, there are no recreational facilities on either of the proposed conversion sites, so what is lost is the potential for future recreational activity at those locations. No cultural resources are lost through the conversion of the Wald Park parcels. It is assumed there will be no adverse cultural or environmental impacts for the planned development of the replacement parcel. Below is further explanation for any items in the ESF checklist which had a response other than Not Applicable or No/Negligible Impacts. WALD PARK Conversion Subject 1 (School Expansion) The only environmental impacts anticipated from the planned use following conversion of the school expansion parcel are the temporary impacts of active construction, which will be mitigated by use of best practices. There may also be minor impacts to traffic within the park during the construction phase. Absent the conversion, the parcel has been and would remain landscape buffer; therefore there are no/negligible impacts to the potential for future recreational use of this 0.25 acre parcel. Conversion Subject 2 (Public Works) Environmental impacts from the planned used following conversion of the public works site could be slightly diminished air quality and increased noise from traffic at the fast food restaurant to be located there. As the property is located along a U.S. highway and is surrounded by the existing noise and traffic of other commercial uses and athletic events, it is not anticipated that impacts to the air quality or noise level would be significant. Circulation/transportation impacts will be minor, as there will continue to be an entrance road to the park at the site. As the entrance to the restaurant will be designed for general public use (whereas the existing public works facility is designed according to limited municipal worker traffic), access to that entry for recreational use may ultimately be improved. (This remains to be seen, as it may depend on the traffic volume for the restaurant.) Community livability will be improved, as presently there is a lack of restaurants along the stretch of US 31 that serves Wald Park. The restaurant will be an option for park users on their way to athletic events and will be convenient for library patrons and the nearby schools. Socioeconomic positive impact is anticipated as the restaurant will generate jobs and tax revenues. Page 22

27 Replacement Property (AVCC) Studies of the AVCC property included in the appendix to this EA are as follows: Jurisdictional Waters Delineation study prepared by Goodwyn Mills & Cawood, (Also included is the U.S. Army Corps of Engineers response.) Spectrum Environmental biological survey,2017, Project University of Alabama Office of Archaeological Research cultural resources study, Below are narrative responses for items on the ESF checklist: Sound Minor impacts to sound at the AVCC site associated with athletic events may be anticipated. Water Quality, Stream Flow, Marine/Estuary, and Floodplain the new park is designed to mitigate the impact of stormwater runoff from adjacent residential development in order to protect the natural resources of the area. Low impact construction methods and utilization of retention ponds in combination with other best practices will be employed such that the park will be protective of the stream as a positive impact. Prior to construction, Section 404 permits will be obtained as required. Traffic/Circulation is being mitigated by the construction of the western entrance. The determination to construct a western entrance rather than the existing eastern entrance was made in response to public opposition of affected residents to the potential traffic. Plant/animal/fish species of special concern and habitat; state/ federal listed or proposed for listing Spectrum Environmental found no suitable habitat for the listed aquatic species and made recommendations to mitigate impact to the listed bat species. Recreational impact the golf course shown in the site map was private country club that has been closed for years. The proposed project will add significantly to the recreational opportunities of the area. Page 23

28 Coordination and Consultation Who worked on this. List persons, organizations and agencies contacted for information and for identifying important issues, developing alternatives or analyzing impacts. Any scoping or other public involvement should be detailed. A list of prepared and their qualifications should be included here. This assessment was prepared by Melissa N. Hipp, MPH, Grants Administrator for the City of Vestavia Hills, with oversight by Christopher Brady, PE, CFM, City Engineer for the City of Vestavia Hills. Christopher Brady, P.E., C.F.M., City Engineer Mr. Brady has served as City Engineer for the City of Vestavia Hills since He has over 15 years of civil design experience in areas such as roadway, drainage, and infrastructure improvement projects. Recent experience includes implementation, review, and permitting of roadway and drainage improvement projects within the City; implementation of the City of Vestavia Hills Regional Walkway master plan; as well as other municipal infrastructure improvement projects. Mr. Brady serves as the City s Flood Plain Manager with memberships including Association of State Flood Plain Managers and Alabama Association of Flood Plain Managers. Below is a list of persons and agencies that were engaged in the studies and public processes that served as the basis of this environmental assessment: Jeffrey Downes, City Manager, City of Vestavia Hills, jdownes@vhal.org Brian C. Davis, Public Service Director, City of Vestavia Hills, bdavis@vhal.org Christopher Brady, City Engineer, City of Vestavia Hills, cbrady@vhal.org Melissa N. Hipp, Grants Coordinator, City of Vestavia Hills, mhipp@vhal.org Vestavia Hills City Council see roster in Appendix H Vestavia Hills Parks and Recreation Board see roster in Appendix Vestavia Hills Planning and Zoning Commission see roster in the Appendix Joey Jones, PE, Geotechnical Dept. Manager, Building & Earth Sciences, Inc., jjones@buildingandearth.com (Role: AVCC Western Access Road) Joe Collums, Asst. Project Manager, Brailsford & Dunlavey, jcollums@programmanagers.com (Role: Recreational Master Plan) Chris Eckroate, PE, Principal, Caprine Engineering, chris.eckroate@caprineeng.com (Role: AVCC Master Plan) Richard A. Nail II, PE LEED AP BD+C, Sr. Principal, LBYD Inc. Civil & Structural Engineers, RNail@lybd.com (Role: Freddy s restaurant, School Expansion) Page 24

29 Greg Ellis, CPE, Director of Preconstruction Services, Hoar Program Management, (Role: School Expansion) Latham Associates (Role: Architects for School Expansion) Joseph F. Breighner Jr., PLS, Vice President, Schoel Consulting Engineers, (Role: School Expansion) Norman Pless, Pless Appraisal, Ed Norton, Principal, Holcomb Norton Partners, (Role: Landscape Architect for AVCC) Justin D. Edwards, Biologist, Goodywn Mills & Cawood (Role: AVCC Jurisdictional Waters Delineation) Dr. A. Brooke Persons, RPA, University of Alabama Office of Archaeological Research, (Role: AVCC Cultural Resources Survey) Brock Reynolds, Natural Resource Specialist, Spectrum Environmental, (Role: AVCC Biological Survey) Concurrences and comments received from the following agencies: o Alabama Historical Commission o US Army Corps of Engineers o US Fish and Wildlife Service o EPA and ADEM were sent letters regarding the project, although any recommendations of these agencies would follow further environmental review, e.g. if the project were not eligible for a FONSI (finding of no significant impact) letter or if special permitting were required to work within the floodplain. Also, how was intergovernmental review handled? Does the State have Clearinghouse process? If yes, has the LWCF Program been selected for review under the State Clearinghouse process? If yes, was this proposal reviewed by the appropriate State, metropolitan, regional and local agencies, and if so, attach any information and comments received about this proposal. If proposal was not reviewed, explain why not applicable Alabama does not have an intergovernmental review process per Executive Order This application was submitted to the Alabama Department of Economic and Community Affairs for review. Public comment periods (how long, when in the process, who was invited to comment) and agency response. A preliminary version of this Environmental Assessment was made publicly available on the City website ( on December 1, 2016 with comments accepted through December 30, That EA did not include letters of concurrence which had been requested. No comments were received. This EA is being posted again October 2017 with comments accepted through November 30, This EA will be updated following the conclusion of the period of public comment. Any formal decision and supporting reasons regarding degree of potential impacts to the human environment. None. Page 25

30 Was this proposal part of any other federal action? If so, what was analyzed and what impacts were identified? Provide specific environmental review document references. This proposal is not part of any other federal action. Page 26

31 Appendix CONTENTS I. Environmental Screening Form and NEPA Pathway Recommendation I(a) ESF Checklist for Wald Park I(b) ESF Checklist for AVCC II. Maps and Drawings III. Property Documents IV. Technical Documents / Study Findings V. Letters of Concurrence and Comments VI. Banking and Future Conversion Potential VII. Public Involvement LWCF Project Amendment Application Cover Page

32 Appendix I Environmental Screening Form LWCF Proposal Description and Environmental Screening Form The purpose of this Proposal Description and Environmental Screening Form (PD/ESF) is to provide descriptive and environmental information about a variety of Land and Water Conservation Fund (LWCF) state assistance proposals submitted for National Park Service (NPS) review and decision. The completed PD/ESF becomes part of the federal administrative record in accordance with the National Environmental Policy Act (NEPA) and its implementing regulations. The PD portion of the form captures administrative and descriptive details enabling the NPS to understand the proposal. The ESF portion is designed for States and/or project sponsors to use while the LWCF proposal is under development. Upon completion, the ESF will indicate the resources that could be impacted by the proposal enabling States and/or project sponsors to more accurately follow an appropriate pathway for NEPA analysis: 1) a recommendation for a Categorical Exclusion (CE), 2) production of an Environmental Assessment (EA), or 3) production of an Environmental Impact Statement (EIS). The ESF should also be used to document any previously conducted yet still viable environmental analysis if used for this federal proposal. The completed PD/ESF must be submitted as part of the State s LWCF proposal to NPS. Except for the proposals listed below, the PD/ESF must be completed, including the appropriate NEPA document, signed by the State, and submitted with each new federal application for LWCF assistance and amendments for: scope changes that alter or add facilities and/or acres; conversions; public facility exceptions; sheltering outdoor facilities; and changing the original intended use of an area from that which was approved in an earlier LWCF agreement. Consult the LWCF Program Manual ( for detailed guidance for your type of proposal and on how to comply with NEPA. For the following types of proposals only this Cover Page is required because these types of proposals are administrative in nature and are categorically excluded from further NEPA environmental analysis. NPS will complete the NEPA CE Form. Simply check the applicable box below, and complete and submit only this Cover Page to NPS along with the other items required for your type of proposal as instructed in the LWCF Program Manual. SCORP planning proposal 28

33 Time extension with no change in project scope or with a reduction in project scope To delete work and no other work is added back into the project scope To change project cost with no change in project scope or with a reduction in project scope To make an administrative change that does not change project scope Name of LWCF Proposal: >>>>>>>>>>> Expedited Review Requested Date Submitted to NPS: Submitted to SLO (ADECA) Conversion Two Small Parcels of Wald Park with Replacement by Recreational Area at the Former Altadena Valley Country Club Prior LWCF Project Number(s) List all prior LWCF project numbers and all park names associated with assisted site(s): Wald Park LWCF Local or State Project Sponsoring Agency (recipient or sub-recipient in case of pass-through grants): CITY OF VESTAVIA HILLS Local or State Sponsor Contact: Name/Title: JEFFREY DOWNES, CITY MANAGER Office/Address: 1032 MONTGOMERY HIGHWAY VESTAVIA HILLS, AL Phone/Fax: / jdownes@vhal.org 29

34 Using a separate sheet for narrative descriptions and explanations, address each item and question in the order it is presented, and identify each response with its item number such as Step 1-A1, A2; Step 3-B1; Step 6-A1, A29; etc. Step 1. Type of LWCF Proposal New Project Application Acquisition Development Combination (Acquisition & Development) Go to Step 2A Go to Step 2B Go to Step 2C _X Project Amendment Increase in scope or change in scope from original agreement. Complete Steps 3A, and 5 through 7. 6(f) conversion proposal. Complete Steps 3B, and 5 through 7. Request for public facility in a Section 6(f) area. Complete Steps 3C, and 5 through 7. Request for temporary non-conforming use in a Section 6(f) area. Complete Steps 4A, and 5 through 7. Request for significant change in use/intent of original LWCF application. Complete Steps 4B, and 5 through 7. Request to shelter existing/new facility within a Section 6(f) area regardless of funding source. Complete Steps 4C, and 5 through 7. Step 2. New Project Application (See LWCF Manual for guidance.) A. For an Acquisition Project 1. Provide a brief narrative about the proposal that provides the reasons for the acquisition, the number of acres to be acquired with LWCF assistance, and a description of the property. Describe and quantify the types of existing resources and features on the site (for example, 50 acres wetland, 2,000 feet beachfront, 200 acres forest, scenic views, 100 acres riparian, vacant lot, special habitat, any unique or special features, recreation amenities, historic/cultural resources, hazardous materials/ contamination history, restrictions, institutional controls, easements, rights-of-way, above ground/underground utilities, including wires, towers, etc.). 30

35 2. How and when will the site be made open and accessible for public outdoor recreation use (signage, entries, parking, site improvements, allowable activities, etc.)? 3. Describe development plans for the proposal for the site(s) for public outdoor recreation use within the next three (3) years. 4. SLO must complete the State Appraisal/Waiver Valuation Review form in Step 7 certifying that the appraisal(s) has been reviewed and meets the Uniform Appraisal Standards for Federal Land Acquisitions or a waiver valuation was approved per 49 CFR (c)(2)(ii). State should retain copies of the appraisals and make them available if needed. 5. Address each item in D below. B. For a Development Project 1. Describe the physical improvements and/or facilities that will be developed with federal LWCF assistance, including a site sketch depicting improvements, where and how the public will access the site, parking, etc. Indicate entrances on 6(f) map. Indicate to what extent the project involves new development, rehabilitation, and/or replacement of existing facilities. 2. When will the project be completed and open for public outdoor recreation use? 3. Address each item in D below. 31

36 C. For a Combination Project 1. For the acquisition part of the proposal: a. Provide a brief narrative about the proposal that provides the reasons for the acquisition, number of acres to be acquired with LWCF assistance, and describes the property. Describe and quantify the types of existing resources and features on the site (for example, 50 acres wetland, 2,000 feet beachfront, 200 acres forest, scenic views, 100 acres riparian, vacant lot, special habitat, any unique or special features, recreation amenities, historic/cultural resources, hazardous materials/ contamination history, restrictions, institutional controls, easements, rights-of-way, above ground/underground utilities, including wires, towers, etc.) b. How and when will the site be made open and accessible for public outdoor recreation use (signage, entries, parking, site improvements, allowable activities, etc.)? c. Describe development plans for the proposed for the site(s) for public outdoor recreation use within the next three (3) years. d. SLO must complete the State Appraisal/Waiver Valuation Review form in Step 7 certifying that the appraisal(s) has been reviewed and meets the Uniform Appraisal Standards for Federal Land Acquisitions or a waiver valuation was approved per 49 CFR (c)(2)(ii). State should retain copies of the appraisals and make them available if needed. 2. For the development part of the proposal: a. Describe the physical improvements and/or facilities that will be developed with federal LWCF assistance, including a site sketch depicting improvements, where and how the public will access the site, parking, etc. Indicate entrances on 6(f) map. Indicate to what extent the project involves new development, rehabilitation, and/or replacement of existing facilities. b. When will the project be completed and open for public outdoor recreation use? 3. Address each item in D below. D. Additional items to address for a new application and amendments 1. Will this proposal create a new public park/recreation area where none previously existed and is not an addition to an existing public park/recreation area? Yes (go to #3) No (go to #2) 2 a. What is the name of the pre-existing public area that this new site will be added to? b. Is the pre-existing public park/recreation area already protected under Section 6(f)? Yes No If no, will it now be included in the 6(f) boundary? Yes No 3. What will be the name of this new public park/recreation area? 4. a. Who will hold title to the property assisted by LWCF? Who will manage and operate the site(s)? b. What is the sponsor s type of ownership and control of the property? Fee simple ownership Less than fee simple. Explain: 32

37 Lease. Describe lease terms including renewable clauses, # of years remaining on lease, etc. Who will lease area? Submit copy of lease with this PD/ESF. (See LWCF Manual for program restrictions for leases and further guidance.) 5. Describe the nature of any rights-of-way, easements, reversionary interests, etc. to the Section 6(f) park area? Indicate the location on 6(f) map. Do parties understand that a Section 6(f) conversion may occur if private or non-recreation activities occur on any pre-existing right-of-way, easement, leased area? 6. Are overhead utility lines present, and if so, explain how they will be treated per LWCF Manual. 7. As a result of this project, describe new types of outdoor recreation opportunities and capacities, and short and long term public benefit 33

38 8. Explain any existing non-recreation and non-public uses that will continue on the site(s) and/or proposed for the future within the 6(f) boundary. 9. Describe the planning process that led to the development of this proposal. Your narrative should address: a. How was the interested and affected public notified and provided opportunity to be involved in planning for and developing your LWCF proposal? Who was involved and how were they able to review the completed proposal, including any state, local, federal agency professionals, subject matter experts, members of the public and Indian Tribes. Describe any public meetings held and/or formal public comment periods, including dates and length of time provided for the public to participate in the planning process and/or to provide comments on the completed proposal. b. What information was made available to the public for review and comment? Did the sponsor provide written responses addressing the comments? If so, include responses with this PD/ESF submission. 10. How does this proposal implement statewide outdoor recreation goals as presented in the Statewide Comprehensive Outdoor Recreation Plan (SCORP) (include references), and explain why this proposal was selected using the State s Open Project Selection Process (OPSP). 11. List all source(s) and amounts of financial match to the LWCF federal share of the project. The value of the match can consist of cash, donation, and in-kind contributions. The federal LWCF share and financial matches must result in a viable outdoor recreation area and not rely on other funding not mentioned here. Other federal resources may be used as a match if specifically authorized by law. Source Type of Match Value $ 12. Is this LWCF project scope part of a larger effort not reflected on the SF-424 (Application for Federal Assistance) and grant agreement? If so, briefly describe the larger effort, funding amount(s) and source(s). This will capture information about partnerships and how LWCF plays a role in leveraging funding for projects beyond the scope of this federal grant. 13. List all required federal, state, and local permits/approvals needed for the proposal and explain their purpose and status. Proceed to Steps 5 through 7 Step 3. Project Amendment (See LWCF Manual for guidance.) A. Increase/Change in Project Scope 34

39 1. For Acquisition Projects: To acquire additional property that was not described in the original project proposal and NEPA documentation, follow Step 2A-Acquisition Project and 2D. 2. For Development Projects: To change the project scope for a development project that alters work from the original project scope by adding elements or enlarging facilities, follow Step 2B-Development Project and 2D. 3. For Combination Projects: Follow Step 2C as appropriate. B. Section 6(f)(3) Conversion Proposal Prior to developing your Section 6(f)(3) conversion proposal, you must consult the LWCF Manual and 36 CFR 59.3 for complete guidance on conversions. Local sponsors must consult early with the State LWCF manager when a conversion is under consideration or has been discovered. States must consult with their NPS-LWCF manager as early as possible in the conversion process for guidance and to sort out and discuss details of the conversion proposal to avoid mid-course corrections and unnecessary delays. A critical first step is for the State and NPS to agree on the size of the Section 6(f) park land impacted by any non-recreation, non-public use, 35

40 especially prior to any appraisal activity. Any previous LWCF project agreements and actions must be identified and understood to determine the actual Section 6(f) boundary. The Section 6(f)(3) conversion proposal including the required NEPA environmental review documents (CE recommendation or an EA document) must focus on the loss of public outdoor recreation park land and recreational usefulness, and its replacement per 36 CFR 59, and not the activities precipitating the conversion or benefits thereof, such as the impacts of constructing a new school to relieve overcrowding or constructing a hotel/restaurant facility to stimulate the local economy. Rather, the environmental review must 1) focus on resource impacts as indicated on the ESF (Step 6), including the loss of public park land and recreation opportunities (ESF A-15), and 2) the impacts of creating new replacement park land and replacement recreation opportunities. A separate ESF must be generated for the converted park area and each replacement site. Section 6(f)(3) conversions always have more than minor impacts to outdoor recreation (ESF A-15) as a result of loss of parkland requiring an EA, except for small conversions as defined in the LWCF Manual Chapter 8. For NPS review and decision, the following elements are required to be included in the State s completed conversion proposal to be submitted to NPS: 1. A letter of transmittal from the SLO recommending the proposal. this would be a letter from ADECA following their review of the application. 2. A detailed explanation of the sponsor s need to convert the Section 6(f) parkland including all efforts to consider other practical alternatives to this conversion, how they were evaluated, and the reasons they were not pursued. see environmental assessment narrative 3. An explanation of how the conversion is in accord with the State Comprehensive Outdoor Recreation Plan (SCORP). see environmental assessment narrative 4. Completed State Appraisal/Waiver Valuation Review form in Step 7 for each of the converted and replacement parcels certifying that the appraisals meet the Uniform Appraisal Standards for Federal Land Acquisitions. States must retain copies of the appraisals/waiver valuations and make them available for review upon request. 5. For the park land proposed for conversion, a detailed description including the following: see environmental assessment narrative a. Specific geographic location on a map, 9-digit zip code, and name of park or recreation area proposed for conversion. b. Description of the area proposed for the conversion including the acreage to be converted and any acreage remaining. For determining the size of the conversion, consider not only the physical footprint of the activity precipitating the conversion, but how the precipitating activity will impact the entire 6(f) park area. In many cases the size of the converted area is larger than the physical footprint. Include a description of the recreation resources, facilities, and recreation opportunities that will be impacted, displaced or lost by the proposed conversion. For proposals to partially convert a Section 6(f) park area, the remaining 6(f) park land must remain recreationally viable and not be impacted by the activities that are precipitating the conversion. If it is anticipated that the precipitating activities impact the remaining Section 6(f) area, the proposed area for the conversion should be expanded to encompass all impacted park land. c. Description of the community and population served by the park, including users of the park and uses. 36

41 d. For partial conversions, a revised 6(f) map clearly indicating both the portion that is being converted and the portion remaining intact under Section 6(f). 6. For each proposed replacement site: see environmental assessment narrative a. Specific geographic location on a map, 9-digit zip code, and geographical relationship of converted and replacement sites. If site will be added to an existing public park/outdoor recreation area, indicate on map. b. Description of the site s physical characteristics and resource attributes with number and types of resources and features on the site, for example, 15 acres wetland, 2,000 feet beachfront, 50 acres forest, scenic views, 75 acres riparian, vacant lot, special habitat, any unique or special features, structures, recreation amenities, historic/cultural resources, hazardous materials/contamination history, restrictions, institutional controls, easements, rights-of-way, overhead/underground utilities including overhead wires, towers, etc. c. Identification of the owner of the replacement site and its recent history of use/function up to the present. d. Detailed explanation of how the proposed replacement site is of reasonably equivalent usefulness and location as the property being converted, including a description of the recreation needs that will be met by the new replacement parks, populations to be served, and new outdoor recreation resources, facilities, and opportunities to be provided. e. Identification of owner and manager of the new replacement park f. Name of the new replacement park. If the replacement park is added to an existing public park area, will the existing area be included within the 6(f) boundary? What is the name of the existing public park area? g. Timeframe for completing the new outdoor recreation area(s) to replace the recreation opportunity lost per the terms of conversion approval and the date replacement park(s) will be open to the public. h. New Section 6(f) map for the new replacement park. 7. NEPA environmental review, including NHPA Section 106 review, for both the converted and replacement sites in the same document to analyze how the converted park land and recreational usefulness will be replaced. Except for small conversions (see LWCF Manual Chapter 8), conversions usually require an EA. Proceed to Steps 5 through 7 C. Proposal for a Public Facility in a Section 6(f) Area Prior to developing this proposal, you must consult the LWCF Manual for complete guidance. In summary, NPS must review and decide on requests to construct a public indoor and/or non-recreation facility within a Section 6(f) area. In certain cases NPS may approve the construction of public facilities within a Section 6(f) area where it can be shown that there will be a net gain in outdoor recreation benefits and enhancements for the entire park. In most cases, development of a non-recreation public facility within a Section 6(f) area constitutes a conversion. For NPS review, the State/sponsor must submit a proposal to NPS under a letter of transmittal from the SLO that: 1. Describes the purpose and all proposed uses of the public facility such as types of programming, recreation activities, and special events including intended users of the new facility and any agency, organization, or other party to occupy the facility. Describe the interior and exterior of the facility, such as office space, 37

42 meeting rooms, food/beverage area, residential/lodging area, classrooms, gyms, etc. Explain how the facility will be compatible with the outdoor recreation area. Explain how the facility and associated uses will significantly support and enhance existing and planned outdoor recreation resources and uses of the site, and how outdoor recreation use will remain the primary function of the site. (The public s outdoor recreation use must continue to be greater than that expected for any indoor use, unless the site is a single facility, such as a swimming pool, which virtually occupies the entire site.) 2. Indicates the exact location of the proposed public facility and associated activities on the site s Section 6(f) map. Explain the design and location alternatives considered for the public facility and why they were not pursued. 3. Explains who will own and/or operate and maintain the facility? Attach any 3 rd party leases and operation and management agreements. When will the facility be open to the public? Will the facility ever be used for private functions and closed to the public? Explain any user or other fees that will be instituted, including the fee structure. 4. Includes required documents as a result of a completed NEPA process (Steps 5 7). Proceed to Steps 5 through 7 Step 4. Proposals for Temporary Non-Conforming Use, Significant Change in Use, and Sheltering Facilities (See LWCF Manual for guidance.) A. Proposal for Temporary Non-Conforming Use Prior to developing this proposal, you must consult the LWCF Manual for complete guidance. NPS must review and decided on requests for temporary uses that do not meet the requirements of allowable activities within a Section 6(f) area. A temporary non-conforming use is limited to a period of six months (180 days) or less. Continued use beyond six-months will not be considered temporary, and may result in a Section 6(f)(3) conversion of use requiring the replacement of converted parkland. For NPS review, describe the temporary non-conforming use (activities other than public outdoor recreation) in detail including the following information: 1. A letter of transmittal from the SLO recommending the proposal. 2. Describe in detail the proposed temporary non-conforming use and all associated activities, why it is needed, and alternative locations that were considered and why they were not pursued. 3. Explain length of time needed for the temporary non-conforming use and why. 4. Describe the size of the Section 6(f) area affected by the temporary non-conforming use activities and expected impacts to public outdoor recreation areas, facilities and opportunities. Explain efforts to keep the size of the area impacted to a minimum. Indicate the location of the non-conforming use on the site s 6(f) map. 5. Describe any anticipated temporary/permanent impacts to the Section 6(f) area and how the sponsor will mitigate them during and after the non-conforming use ceases. 6. Consult the LWCF Manual for additional requirements and guidelines before developing the proposal. Proceed to Steps 5 through 7 B. Proposal for Significant Change in Use Prior to developing the proposal, you must consult the LWCF Manual for complete guidance. NPS approval must be obtained prior to any change from one eligible use to another when the proposed use would significantly contravene the original plans or intent for the area outlined in the original LWCF application for federal assistance. Consult with NPS for early determination on the need for a formal review. NPS approval is only required for proposals that will significantly change the use of a LWCF-assisted site (e.g., from passive to active recreation). 38

43 The proposal must include and address the following items: The Description and Notification Form and Standard Form 424 for Amendments are included in Appendix H of the Environmental Assessment. 1. A letter of transmittal from the SLO recommending the proposal. this will be a letter from ADECA following review of this application. 2. Description of the proposed changes and how they significantly contravene the original plans or intent of LWCF agreements. 3. Explanation of the need for change in use and how the change is consistent with local plans and the SCORP. 4. Consult the LWCF Manual for additional requirements and guidelines before developing the proposal. Proceed to Steps 5 through 7 C. Proposal for Sheltering Facilities Prior to developing this proposal, you must consult the LWCF Manual for complete guidance. NPS must review and decide on all proposals to shelter an existing outdoor recreation facility or construct a new sheltered recreation facility within a Section 6(f) area regardless of funding source. The proposal must demonstrate that there is an increased benefit to public recreation opportunity. Describe the sheltering proposal in detail, including the following: 1. A letter of transmittal from the SLO recommending the proposal. 2. Describe the proposed sheltered facility, how it would operate, how the sheltered facility will include recreation uses that could typically occur outdoors, and how the primary purpose of the sheltered facility is recreation. 39

44 3. Explain how the sheltered facility would not substantially diminish the outdoor recreation values of the site including how the sheltered facility will be compatible and significantly supportive of the outdoor recreation resources present and/or planned. 4. Explain how the sheltered facility will benefit the total park s outdoor recreation use. 5. Describe efforts provided to the public to review the proposal to shelter the facility and has local support. 6. Document that the sheltered facility will be under the control and tenure of the public agency which sponsors and administers the original park area. 7. Consult the LWCF Manual for additional requirements and guidelines before developing the proposal. Proceed to Steps 5 through 7 Step 5. Summary of Previous Environmental Review (including E.O Intergovernmental Review) To avoid duplication of effort and unnecessary delays, describe any prior environmental review undertaken at any time and still viable for this proposal or related efforts that could be useful for understanding potential environmental impacts. Consider previous local, state, federal (e.g. HUD, EPA, USFWS, FHWA, DOT) and any other environmental reviews. At a minimum, address the following: see environmental assessment narrative 1. Date of environmental review(s), purpose for the environmental review(s) and for whom they were conducted. See Appendix D 2. Description of the proposed action and alternatives. 3. Who was involved in identifying resource impact issues and developing the proposal including the interested and affected public, government agencies, and Indian tribes. 4. Environmental resources analyzed and determination of impacts for proposed actions and alternatives. 5. Any mitigation measures to be part of the proposed action. 6. Intergovernmental Review Process (Executive Order 12372): Does the State have an Intergovernmental Review Process? Yes No _X. If yes, has the LWCF Program been selected for review under the State Intergovernmental Review Process? Yes No. If yes, was this proposal reviewed by the appropriate State, metropolitan, regional and local agencies, and if so, attach any information and comments received about this proposal. If proposal was not reviewed, explain why not. 40

45 7. Public comment periods (how long, when in the process, who was invited to comment) and agency response. The formal public comment period for this Environmental Assessment and proposed conversion is October 20, 2017 through November 30,2017. Note, however, that discussion of the planned use of the Altadena Valley Country Club property was discussed publicly through the Community Spaces Plan public meetings held July and August Any formal decision and supporting reasons regarding degree of potential impacts to the human environment. 9. Was this proposed LWCF federal action and/or any other federal actions analyzed/reviewed in any of the previous environmental reviews? If so, what was analyzed and what impacts were identified? Provide specific environmental review document references. Use resource impact information generated during previous environmental reviews described above and from recently conducted site inspections to complete the Environmental Screening Form (ESF) portion of this PD/ESF under Step 6. Your ESF responses should indicate your proposal s potential for impacting each resource as determined in the previous environmental review(s), and include a reference to where the analysis can be found in an earlier environmental review document. If the previous environmental review documents contain proposed actions to mitigate impacts, briefly summarize the mitigation for each resource as appropriate. The appropriate references for previous environmental review document(s) must be documented on the ESF, and the actual document(s) along with this PD/ESF must be included in the submission for NPS review. Step 6. Environmental Screening Form (ESF) Proceed to Steps 6 through 7 41

46 See A(1) ESF Checklist: Wald Park, and A(2) ESF Checklist: AVCC This portion of the PD/ESF is a working tool used to identify the level of environmental documentation which must accompany the proposal submission to the NPS. By completing the ESF, the project sponsor is providing support for its recommendation in Step 7 that the proposal either: 1. meets criteria to be categorically excluded (CE) from further NEPA review and no additional environmental documentation is necessary; or 2. requires further analysis through an environmental assessment (EA) or an environmental impact statement (EIS). An ESF alone does not constitute adequate environmental documentation unless a CE is recommended. If an EA is required, the EA process and resulting documents must be included in the proposal submission to the NPS. If an EIS may be required, the State must request NPS guidance on how to proceed. The scope of the required environmental analysis will vary according to the type of LWCF proposal. For example, the scope for a new LWCF project will differ from the scope for a conversion. Consult the LWCF Manual for guidance on defining the scope or extent of environmental analysis needed for your LWCF proposal. As early as possible in your planning process, consider how your proposal/project may have direct, indirect and cumulative impacts on the human environment for your type of LWCF action so planners have an opportunity to design alternatives to lessen impacts on resources, if appropriate. When used as a planning tool in this way, the ESF responses may change as the proposal is revised until it is ready for submission for federal review. Initiating or completing environmental analysis after a decision has been made is contrary to both the spirit and letter of the law of the NEPA. The ESF should be completed with input from resource experts and in consultation with relevant local, state, tribal and federal governments, as applicable. The interested and affected public should be notified of the proposal and be invited to participate in scoping out the proposal (see LWCF Manual Chapter 4). At a minimum, a site inspection of the affected area must be conducted by individuals who are familiar with the type of affected resources, possess the ability to identify potential resource impacts, and to know when to seek additional data when needed. At the time of proposal submission to NPS for federal review, the completed ESF must justify the NEPA pathway that was followed: CE recommendation, production of an EA, or production of an EIS. The resource topics and issues identified on the ESF for this proposal must be presented and analyzed in an attached EA/EIS. Consult the LWCF Manual for further guidance on LWCF and NEPA. The ESF contains two parts that must be completed: Part A. Environmental Resources Part B. Mandatory Criteria 42

47 Part A: For each environmental resource topic, choose an impact estimate level (none, negligible, minor, exceeds minor) that describes the degree of potential negative impact for each listed resource that may occur directly, indirectly and cumulatively as a result of federal approval of your proposal. For each impacted resource provide a brief explanation of how the resource might be affected, how the impact level was determined, and why the chosen impact level is appropriate. If an environmental review has already been conducted on your proposal and is still viable, include the citation including any planned mitigation for each applicable resource, and choose an impact level as mitigated. If the resource does not apply to your proposal, mark NA in the first column. Add any relevant resources (see A.24 on the ESF) if not included in the list. Use a separate sheet to briefly clarify how each resource could be adversely impacted; any direct, indirect, and cumulative impacts that may occur; and any additional data that still needs to be determined. Also explain any planned mitigation already addressed in previous environmental reviews. Part B: This is a list of mandatory impact criteria that preclude the use of categorical exclusions. If you answer yes or maybe for any of the mandatory criteria, you must develop an EA or EIS regardless of your answers in Part A. Explain all yes and maybe answers on a separate sheet. For conversions, complete one ESF for each of the converted and replacement sites. The Environmental Screening Forms for both the converted and the replacement sites are included in the Appendix (A1 and A2) of the Environmental Assessment for this proposal. Narrative explanations of both negative and positive impacts are included in the Environmental Impact section of that document. Environmental Reviewers The following individual(s) provided input in the completion of the environmental screening form. List all reviewers including name, title, agency, field of expertise. Keep all environmental review records and data on this proposal in state compliance file for any future program review and/or audit. The ESF may be completed as part of a LWCF pre-award site inspection if conducted in time to contribute to the environmental review process for the proposal. 2. Christopher Brady, PE, CFPM, City Engineer, City of Vestavia Hills review of the prepared ESF 3. Melissa Hipp, MPH, Assistant to the City Manager, City of Vestavia Hills preparation of the ESF 4. Please see Appendix D for technical reviews used to inform this EA The following individuals conducted a site inspection to verify field conditions. 43

48 List name of inspector(s), title, agency, and date(s) of inspection. 1. Responses to this form are based on staff familiarity with sites due to regular visits to the areas for general purposes at the Conversion Subject Parcels (Public Works, 1280 Montgomery Highway, and 1965 Merryvale Road, Vestavia Hills, AL 35216) and for oversight of development near the proposed replacement parcel (old Altadena Valley Country Club) State may require signature of LWCF sub-recipient applicant here: Date Step 7. Recommended NEPA Pathway and State Appraisal/Waiver Valuation First, consult the attached list of Categorical Exclusions (CEs) for Which a Record is Needed. If you find your action in the CE list and you have determined in Step 6A that impacts will be minor or less for each applicable environmental resource on the ESF and you answered no to all of the Mandatory Criteria questions in Step 6B, the proposal qualifies for a CE. Complete the following State LWCF Environmental Recommendations box indicating the CE recommendation. If you find your action in the CE list and you have determined in Step 6A that impacts will be greater than minor or that more data is needed for any of the resources and you answered no to all of the Mandatory Criteria questions, your environmental review team may choose to do additional analysis to determine the context, duration, and intensity of the impacts of your project or may wish to revise the proposal to minimize impacts to meet the CE criteria. If impacts remain at the greater than minor level, the State/sponsor must prepare an EA for the proposal. Complete the following State Environmental Recommendations box indicating the need for an EA. If you do not find your action in the CE list, regardless of your answers in Step 6, you must prepare an EA or EIS. Complete the following State Environmental Recommendations box indicating the need for an EA or EIS. 44

49 State NEPA Pathway Recommendation xi certify that a site inspection was conducted for each site involved in this proposal and to the best of my knowledge, the information provided in this LWCF Proposal Description and Environmental Screening Form (PD/ESF) is accurate based on available resource data. All resulting notes, reports and inspector signatures are stored in the state s NEPA file for this proposal and are available upon request. On the basis of the environmental impact information for this LWCF proposal as documented in this LWCF PD/ESF with which I am familiar, I recommend the following LWCF NEPA pathway: This proposal qualifies for a Categorical Exclusion (CE). CE Item #: Explanation: x This proposal requires an Environmental Assessment (EA) which is attached and has been produced by the State/sponsor in accordance with the LWCF Program Manual. This proposal may require an Environmental Impact Statement (EIS). NPS guidance is requested per the LWCF Program Manual. Reproduce this certificate as necessary. Complete for each LWCF appraisal or waiver valuation. State Appraisal/Waiver Valuation Review Property address: Proposed Replacement Property Address TBD (formerly 2651 Alta Vista Drive, Birmingham, AL 35243) Real property value: $ 1,500,000 Effective date of value: 5/16/2017 I certify that: xa State-certified Review Appraiser has reviewed the appraisal and has determined that it was prepared in conformity with the Uniform Appraisal Standards for Federal Land Acquisitions. OR the State has reviewed and approved a waiver valuation for this property per 49 CFR (c)(2)(ii). 45

50 Reproduce this certificate as necessary. Complete for each LWCF appraisal or waiver valuation. State Appraisal/Waiver Valuation Review Property address: Conversion Subject Property 1 Adjacent to 1965 Merryvale Rd, Vestavia Hills, AL Real property value: $ 26,000 Effective date of value: 5/16/2017 I certify that: x a State-certified Review Appraiser has reviewed the appraisal and has determined that it was prepared in conformity with the Uniform Appraisal Standards for Federal Land Acquisitions. OR the State has reviewed and approved a waiver valuation for this property per 49 CFR (c)(2)(ii). Reproduce this certificate as necessary. Complete for each LWCF appraisal or waiver valuation. State Appraisal/Waiver Valuation Review Property address: Conversion Subject Property Montgomery Highway, Vestavia Hills, AL Real property value: $ 1,350,000 Effective date of value: 5/16/2017 I certify that: x a State-certified Review Appraiser has reviewed the appraisal and has determined that it was prepared in conformity with the Uniform Appraisal Standards for Federal Land Acquisitions. OR the State has reviewed and approved a waiver valuation for this property per 49 CFR (c)(2)(ii). SLO/ASLO Original Signature: Date: Typed Name, Title, Agency: 46

51 National Environmental Policy Act National Park Service-Land and Water Conservation Fund State Assistance Program Categorical Exclusions for Which a Record is Needed Note: The following are the NEPA Categorical Exclusions approved for use with all NPS programs. Only the unshaded categories apply to LWCF proposals. Before selecting a categorical exclusion (CE), complete the PD/ESF for the LWCF proposal to support the CE selection. A. Actions related to general administration (1) Changes or amendments to an approved action when such changes would cause no environmental impact. LWCF actions that are covered include amendments for: - time extensions with no change in project scope or with a reduction in project scope; -deleting work and no other work is added back into the project scope; -changing project cost with no change in project scope or with a reduction in project scope; -making administrative changes that do not affect project scope. (2) Minor boundary changes that are accomplished through existing statutory authorities and that result in no change in land use. (3) Re-issuance/renewal of permits, rights-of-way, or easements not involving new environmental impacts provided that the impacts of the original actions were evaluated in an environmental document. (4) Conversion of existing permits to rights-of-way, when such conversions neither continue nor potentially initiate adverse environmental conditions, provided that the impacts of the original actions were evaluated in an environmental document. (5) Issuances, extensions, renewals, re-issuances, or minor modifications of concession contracts or permits that do not entail new construction or any potential for new environmental impact as a result of concession operations. (6) Incidental business permits (formerly called commercial use licenses) involving no construction or potential for new environmental impact. (7) Leasing of historic properties in accordance with 36 CFR 18 and NPS-38. (8) Modifications or revisions to existing regulations, or the promulgation of new regulations for NPS-administered areas, provided the modifications, revisions, or new regulations do not: (a) increase public use to the extent of compromising the nature and character of the area or cause physical damage to it. 47

52 (b) introduce non-compatible uses that might compromise the nature and characteristics of the area or cause physical damage to it. (c) conflict with adjacent ownerships or land uses. (d) cause a nuisance to adjacent owners or occupants (9) At the direction of the NPS responsible official, actions where NPS has concurrence or co-approval with another bureau and the action is a CE for that bureau, and where NPS agrees that there is no potential for environmental impact. (10) Routine transfers of jurisdiction between the NPS and the District of Columbia accomplished through existing statutory authority, where no change of use in the land is anticipated upon transfer. B. Plans, studies, and reports (1) Changes or amendments to an approved plan, when such changes have no potential for environmental impact. (2) Cultural resources maintenance guides, collection management plans, and historic furnishings reports. (3) Interpretive plans (interpretive prospectuses, audio-visual plans, museum exhibit plans, wayside exhibit plans). (4) Plans, including priorities, justifications, and strategies, for non-manipulative research, monitoring, inventorying, and information-gathering. (5) Agreements between NPS offices for plans and studies. (6) Authorization, funding, or approval for the preparation of statewide comprehensive outdoor recreation plans (SCORPs). (7) Adoption or approval of academic or research surveys, studies, reports, and similar documents that do not contain and will not result in NPS recommendations. (8) Land protection plans that propose changes to existing land or visitor use when the changes have no potential for environmental impact. C. Actions related to development (1) Land acquisition within established park boundaries, if future anticipated uses would have no potential for environmental impact. (2) Land exchanges that will not lead to anticipated changes in the use of land and that have no potential for environmental impact. For LWCF, some small conversions may meet this criterion. See the LWCF Manual Chapter 8 for further guidance. (3) Routine maintenance and repairs to non-historic structures, facilities, utilities, grounds, and trails. (4) Routine maintenance and repairs to cultural resource sites, structures, utilities, and grounds if the action falls under an approved Historic Structures Preservation Guide or Cyclic Maintenance Guide or if the action would not adversely affect the cultural resource. (5) Installation of LWCF eligible signs, displays, and kiosks. (6) Installation of navigation aids. 48

53 (7) Experimental testing of short duration (no more than one season) of mass transit systems, and changes in operation of existing systems, that have no potential for environmental impact. (8) Replacement in kind of minor structures and facilities with little or no change in location, capacity, or appearance-- for example, comfort stations, pit toilets, fences, kiosks, signs and campfire circles. (9) Repair, resurfacing, striping, installation of traffic control devices, and repair/replacement of guardrails, culverts, signs, and other minor existing features on existing roads when no potential for environmental impact exists. (10) Changes in sanitary facilities operation resulting in no new environmental effects. (11) Installation of wells, comfort stations, and pit or vault toilets in areas of existing use and in developed areas. (12) Minor trail relocation or development of compatible trail networks on logging roads or other established routes. (13) Upgrading or adding new overhead utility facilities on existing poles, or on replacement poles that do not change existing pole line configurations. (14) Issuance of rights-of-way for overhead utility lines to an individual building or well from an existing line where installation will not result in visual intrusion and will involve no clearance of vegetation other than for placement of poles. (15) Issuance of rights-of-way for minor overhead utility lines not involving placement of poles or towers and not involving vegetation management or visual intrusion in an area administered by NPS. (16) Installation of underground utilities in areas showing clear evidence of recent human disturbance or areas within an existing road prism or within an existing overhead utility right-of-way. (17) Minor landscaping in areas showing clear evidence of recent human disturbance. (18) Installation of fencing enclosures, exclosures, or boundary fencing posing no effect on wildlife migrations. D. Actions related to visitor use (1) Minor changes in amounts or types of visitor use for the purpose of ensuring visitor safety or resource protection in accordance with existing regulations. (2) Minor changes in programs and regulations pertaining to visitor activities. (3) Issuance of permits for demonstrations, gatherings, ceremonies, concerts, arts and crafts shows, and so forth, entailing only short-term or readily remediable environmental disturbance. (4) Designation of trailside camping zones with minimal or no improvements. E. Actions related to resource management and protection (1) Archeological surveys and permits involving only surface collection or small-scale test excavations. (2) Restoration of non-controversial (based on internal scoping requirements in section 2.6) native species into suitable habitats within their historic range. 49

54 (3) Removal of individual members of a non-threatened/endangered species or populations of pests and exotic plants that pose an imminent danger to visitors or an immediate threat to park resources. (4) Removal of non-historic materials and structures in order to restore natural conditions when the removal has no potential for environmental impacts, including impacts to cultural landscapes or archeological resources. (5) Development of standards for, and identification, nomination, certification, and determination of, eligibility of properties for listing in the National Register of Historic Places, the National Historic Landmark and National Natural Landmark Programs, and biosphere reserves. (6) Non-destructive data collection, inventory (including field, aerial, and satellite surveying and mapping), study, research, and monitoring activities (this is also a Departmental CE). (7) Designation if environmental study areas and research natural areas, including those closed temporarily or permanently to the public, unless the potential for environmental (including socioeconomic) impact exists. F. Actions related to grant programs (1) Proposed actions essentially the same as those listed in paragraphs A-E above not shaded in gray. (2) Grants for acquisition to areas that will continue in the same use or lower density use with no additional disturbance to the natural setting or type of use. (3) Grants for replacement or renovation of facilities at their same location without altering the kind and amount of recreational, historical, or cultural resources of the area or the integrity of the existing setting. (4) Grants for construction of facilities on lands acquired under a previous NPS or other federal grant, provided that the development is in accord with plans submitted with the acquisition grant, and that environmental documents have been completed on the impacts of the proposal funded by the original grant. (5) Grants for the construction of new facilities within an existing park or recreation area, provided that the facilities will not: (a) conflict with adjacent ownerships or land use, or cause a nuisance to adjacent owners or occupants, such as would happen if use were extended beyond daylight hours. (b) introduce motorized recreation vehicles, including off-road vehicles, personal water craft, and snowmobiles. (c) introduce active recreation pursuits into a passive recreation area. (d) increase public use or introduce non-compatible uses to the extent of compromising the nature and character of the property or causing physical damage to it. (e) add or alter access to the park from the surrounding area. (6) Grants for the restoration, rehabilitation, stabilization, preservation, and reconstruction (or the authorization thereof) of properties listed on or eligible for listing on the National Register of Historic Places, at their same location, and provided that such actions: 50

55 (a) will not alter the integrity of the property or its setting (b) will not increase public use of the area to the extent of compromising the nature and character o the property. Appendix I(a) 51

56 Environmental Screening Form WALD PARK Includes Conversion Subject 1(School Expansion) and Conversion Subject 2 (Public Works) A. ENVIRONMENTAL RESOURCES Indicate potential for adverse impacts. Use a separate sheet to clarify responses per instructions for Part A on page Geological resources: soils, bedrock, slopes, streambeds, landforms, etc. 2. Air quality 3. Sound (noise impacts) 4. Water quality/quantity 5. Stream flow characteristics 6. Marine/estuarine 7. Floodplains/wetlands 8. Land use/ownership patterns; property values; community livability 9. Circulation, transportation 10. Plant/animal/fish species of special concern and habitat; state/ federal listed or proposed for listing 11. Unique ecosystems, such as biosphere reserves, World Heritage sites, old growth forests, etc. 12. Unique or important wildlife/ wildlife habitat 13. Unique or important fish/habitat 14. Introduce or promote invasive species (plant or animal) 15. Recreation resources, land, parks, open space, conservation areas, rec. trails, facilities, services, opportunities, public access, etc. Most conversions exceed minor impacts. See Step 3.B 16. Accessibility for populations with disabilities 17. Overall aesthetics, special characteristics/features 18. Historical/cultural resources, including landscapes, ethnographic, archeological, structures, etc. Attach SHPO/THPO determination. 19. Socioeconomics, including employment, occupation, income changes, tax base, infrastructure positive impact 20. Minority and low-income populations 21. Energy resources (geothermal, fossil fuels, etc.) 22. Other agency or tribal land use plans or policies 23. Land/structures with history of contamination/hazardous materials even if remediated Not Applicable- Resource does not exist No/Negligible Impacts- Exists but no or negligible impacts Minor Impacts Impacts Exceed Minor EA/EIS required More Data Needed to Determine Degree of Impact EA/EIS required 52

57 24. Other important environmental resources to address. B. MANDATORY CRITERIA If your LWCF proposal is approved, would it 1. Have significant impacts on public health or safety? 2. Have significant impacts on such natural resources and unique geographic characteristics as historic or cultural resources; park, recreation, or refuge lands, wilderness areas; wild or scenic rivers; national natural landmarks; sole or principal drinking water aquifers; prime farmlands; wetlands (E.O ); floodplains (E.O 11988); and other ecologically significant or critical areas. 3. Have highly controversial environmental effects or involve unresolved conflicts concerning alternative uses of available resources [NEPA section 102(2)(E)]? 4. Have highly uncertain and potentially significant environmental effects or involve unique or unknown environmental risks? 5. Establish a precedent for future action or represent a decision in principle about future actions with potentially significant environmental effects? 6. Have a direct relationship to other actions with individually insignificant, but cumulatively significant, environmental effects? 7. Have significant impacts on properties listed or eligible for listing on the National Register of Historic Places, as determined by either the bureau or office.(attach SHPO/THPO Comments) 8. Have significant impacts on species listed or proposed to be listed on the List of Endangered or Threatened Species, or have significant impacts on designated Critical Habitat for these species. 9. Violate a federal law, or a state, local, or tribal law or requirement imposed for the protection of the environment? 10. Have a disproportionately high and adverse effect on low income or minority populations (Executive Order 12898)? 11. Limit access to and ceremonial use of Indian sacred sites on federal lands by Indian religious practitioners or significantly adversely affect the physical integrity of such sacred sites (Executive Order 13007)? 12. Contribute to the introduction, continued existence, or spread of noxious weeds or non-native invasive species known to occur in the area, or actions that may promote the introduction, growth, or expansion of the range of such species (Federal Noxious Weed Control Act and Executive Order 13112)? Yes No To be determined Environmental Reviewers The following individual(s) provided input in the completion of the environmental screening form. List all reviewers including name, title, agency, field of expertise. Keep all environmental review records and data on this proposal in state compliance file for any future program review and/or audit. The ESF may be completed as part of a LWCF pre-award site inspection if conducted in time to contribute to the environmental review process for the proposal. 1.Christopher Brady, PE, CFPM, City Engineer, City of Vestavia Hills review of ESF 2.Melissa N. Hipp, Asst. to the City Manager preparation of ESF Wald Park Conversion Subjects 1 and 2 3. The following individuals conducted a site inspection to verify field conditions. List name of inspector(s), title, agency, and date(s) of inspection. 53

58 1. Responses to this form are based on staff familiarity with sites due to regular visits to the areas for general purposes at the Conversion Subject Parcels (Public Works, 1280 Montgomery Highway and 1965 Merryvale Rd., Vestavia Hills, AL 35216) and for oversight of development near the proposed replacement parcel (old Altadena Valley Country Club)

59 Appendix I(b) Environmental Screening Form AVCC Replacement Parcel A. ENVIRONMENTAL RESOURCES Indicate potential for adverse impacts. Use a separate sheet to clarify responses per instructions for Part A on page Geological resources: soils, bedrock, slopes, streambeds, landforms, etc. 2. Air quality Not Applicable- Resource does not exist No/Negligible Impacts- Exists but no or negligible impacts Minor Impacts Impacts Exceed Minor EA/EIS required More Data Needed to Determine Degree of Impact EA/EIS required 3. Sound (noise impacts) 4. Water quality/quantity 5. Stream flow characteristics 6. Marine/estuarine 7. Floodplains/wetlands 8. Land use/ownership patterns; property values; community livability 9. Circulation, transportation 10. Plant/animal/fish species of special concern and habitat; state/ federal listed or proposed for listing 11. Unique ecosystems, such as biosphere reserves, World Heritage sites, old growth forests, etc. 12. Unique or important wildlife/ wildlife habitat 13. Unique or important fish/habitat 14. Introduce or promote invasive species (plant or animal) 15. Recreation resources, land, parks, open space, conservation areas, rec. trails, facilities, services, opportunities, public access, etc. Most conversions exceed minor impacts. See Step 3.B 16. Accessibility for populations with disabilities 17. Overall aesthetics, special characteristics/features 18. Historical/cultural resources, including landscapes, ethnographic, archeological, structures, etc. Attach SHPO/THPO determination. 19. Socioeconomics, including employment, occupation, income changes, tax base, infrastructure 20. Minority and low-income populations 21. Energy resources (geothermal, fossil fuels, etc.) 22. Other agency or tribal land use plans or policies 55

60 23. Land/structures with history of contamination/hazardous materials even if remediated 24. Other important environmental resources to address. B. MANDATORY CRITERIA If your LWCF proposal is approved, would it 1. Have significant impacts on public health or safety? 2. Have significant impacts on such natural resources and unique geographic characteristics as historic or cultural resources; park, recreation, or refuge lands, wilderness areas; wild or scenic rivers; national natural landmarks; sole or principal drinking water aquifers; prime farmlands; wetlands (E.O ); floodplains (E.O 11988); and other ecologically significant or critical areas. 3. Have highly controversial environmental effects or involve unresolved conflicts concerning alternative uses of available resources [NEPA section 102(2)(E)]? 4. Have highly uncertain and potentially significant environmental effects or involve unique or unknown environmental risks? 5. Establish a precedent for future action or represent a decision in principle about future actions with potentially significant environmental effects? 6. Have a direct relationship to other actions with individually insignificant, but cumulatively significant, environmental effects? 7. Have significant impacts on properties listed or eligible for listing on the National Register of Historic Places, as determined by either the bureau or office.(attach SHPO/THPO Comments) 8. Have significant impacts on species listed or proposed to be listed on the List of Endangered or Threatened Species, or have significant impacts on designated Critical Habitat for these species. 9. Violate a federal law, or a state, local, or tribal law or requirement imposed for the protection of the environment? 10. Have a disproportionately high and adverse effect on low income or minority populations (Executive Order 12898)? 11. Limit access to and ceremonial use of Indian sacred sites on federal lands by Indian religious practitioners or significantly adversely affect the physical integrity of such sacred sites (Executive Order 13007)? 12. Contribute to the introduction, continued existence, or spread of noxious weeds or non-native invasive species known to occur in the area, or actions that may promote the introduction, growth, or expansion of the range of such species (Federal Noxious Weed Control Act and Executive Order 13112)? Yes No To be determined Environmental Reviewers The following individual(s) provided input in the completion of the environmental screening form. List all reviewers including name, title, agency, field of expertise. Keep all environmental review records and data on this proposal in state compliance file for any future program review and/or audit. The ESF may be completed as part of a LWCF pre-award site inspection if conducted in time to contribute to the environmental review process for the proposal. 1.Christopher Brady, PE CFPM, City Engineer, City of Vestavia Hills- review of ESF 2.Melissa Hipp, Assistant to the City Manager-preparation of ESF AVCC Replacement Parcel 56

61 3. The following individuals conducted a site inspection to verify field conditions. List name of inspector(s), title, agency, and date(s) of inspection. 1. Responses to this form are based on staff familiarity with sites due to regular visits to the areas for general purposes at the Conversion Subject Parcels (Public Works, 1280 Montgomery Highway, and 1965 Merryvale Road, Vestavia Hills, AL 35216) and for oversight of development near the proposed replacement parcel (old Altadena Valley Country Club) Determination 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. Preparer Signature: Date: Name/Title/Organization: Certifying Officer Signature: Date: Name/Title: This original, signed document and related supporting material must be retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project in accordance with recordkeeping requirements for LWCF program(s). 57

62 Appendix II Maps and Drawings See electronic version of this Environmental Assessment (EA) or refer to print version to see these documents, several of which are larger versions of figures within the EA. Wald Park Site Map Wald Park Section 6f Map with Overlay Wald Park Proposed Final Section 6f Map AVCC Site Map (in relation to Wald Park) AVCC Proposed Section 6f Map AVCC Boundary Survey (EDG)- Note: this document does not reflect the proposed Section 6f boundary. It is included so that reviewers may more easily view easements and other data difficult to represent on the Section 6f map. AVCC Conceptual Drawing Freddy s Conceptual Drawing School Expansion Conceptual Drawing 58

63 Appendix III Property Documents See electronic version of this Environmental Assessment (EA) or refer to print version to see these documents. Wald Park 2016 Letter from the City to ADECA regarding Public Works site, with exhibits Deed Altadena Valley Country Club donated property Deeds AVCC Western Access Road purchased properties LWCF Conversion Wald Park prepared by Norman Pless for review by the Alabama Department of Transportation (ALDOT), 4/11/2017 response to ALDOT review, ALDOT letter stating revised appraisal meets compliance, and documents previously submitted to ALDOT: Appraisal Master File submitted 12/30/2016 Appraisal Conversion Subject 1 (School Expansion) Appraisal Conversion Subject2 (Public Works) Appraisal Replacement Property (AVCC) 59

64 Appendix IV Technical Documents/ Study Findings See electronic version of this Environmental Assessment (EA) or refer to print version to see these documents. Jurisdictional Waters Delineation, Altadena Country Club Caprine Engineering, 2015 Response to USFWS Letter Dated December 9, 2016, Ref-2017-TA-0123 (biological survey) Spectrum Environmental, 2017 A Cultural Resources Survey of the Former Altadena Valley Country Club for a Proposed Recreational Development in Shelby and Jefferson Counties, Alabama - University of Alabama Office of Archaeological Research,

65 Appendix V Letters of Concurrence and Comments See electronic version of this Environmental Assessment (EA)or refer to print version to see these documents. Letters of concurrence/comments from the following are included in this appendix: ALDOT determination of compliance with UASFLA appraisal standards AHC concurrence with UA recommendation for finding of no properties (AVCC), AHC US Department of the Interior comments (AVCC), 2017-TA-0123 US Army Corps of Engineers Preliminary Jurisdictional Determination (AVCC), SAM APW Any comments from the EPA and ADEM would follow review of this Environmental Assessment and/or application for a Section 404 permit. 61

66 Appendix VI Banking and Future Conversion Potential The Land and Water Conservation program allows for the banking of market value against future conversion needs when the replacement property market value exceeds the conversion property value: 5. Banking excess fair market value of replacement land for future conversions. The acquisition of one parcel of replacement land may be used in satisfaction of several approved conversions. Excess fair market value (FMV) of a replacement property can be banked for a period not to exceed five years from the date of the initial conversion amendment. During this time period, the same project sponsor may use the remaining value to make up the FMV difference in cases where the subsequent proposed replacement property satisfies the equal usefulness criterion but its appraised FMV falls short of the equal fair market value requirement. The initial replacement property with the excess fair market value may not be used to satisfy the equal usefulness criterion for subsequent conversions unless additional conversions are anticipated by the sponsor at the time of the original conversion request and the accompanying documentation clearly addresses how the replacement property would satisfy the equal usefulness criteria for the original conversion as well as those that are anticipated. (LWCF Manual, eff. 2008) It is the intent of the City of Vestavia Hills to bank both the excess fair market value and the equal usefulness of the replacement property against future conversions at Wald Park. In 2016 a public dialogue was initiated for how the recreational facilities at Wald Park could be updated to meet the present and anticipated needs of the community. What began as began as a discussion of how best to renovate Wald Park quickly evolved into an evaluation of the communities recreational needs as a whole, and the Community Spaces plan was launched. At the time this Environmental Assessment is being prepared (September 2017), the City Council is awaiting the project scope proposal by TCU Consulting. TCU was hired as the program manager for the Community Spaces Plan, and they conducted a series of public meetings to gather input from the community to help prioritize the planned investments and bring greater definition to improvements that had been discussed on a conceptual level. To date the Council has not determined which components of the Community Spaces Plan are approved to be included in the first phase of construction. Wald Park improvements are primary in the project scope that has been presented to the Council, and it may be anticipated that many of the changes at that site will take place over the next five years. Information about the Community Spaces Plan is available on the City s website at While it is not certain that all the changes listed below will be implemented or that they will be implemented in such a fashion as to trigger a conversion, the City is listing below the potential conversions for the purpose of securing the ability to leverage the FMV of the Altadena Valley Country Club replacement property. Locations of these sites are shown in the figure following the table. 62

67 Map Acres (Est.) Current Use 1 Exchange Field ft baseball diamond grass infield/outfield with 2 sets of bleachers. The outfield is sometimes use as rectangle field practice space, which may be replaced with the inclusion of rectangle field space in the Altadena Park acres Landscape buffer for the Public Works site 3 POTENTIAL REPLACEMENT If any exchange of acreage is required for future conversion, the City may propose to use the current Senior Lodge site, which is outside the boundary and indoor recreational space, as a replacement. Proposed Use Multi-Purpose Facility to include pool and/or tennis locker rooms, concessions, and other components in addition to indoor basketball/athletic courts. It is possible this facility may meet the criteria of an outdoor recreation support facility and/or may otherwise meet outdoor recreation criteria as a multi-purpose facility. Supplement the property to be zoned for commercial use (Public Works) Greenspace with landscape architecture to include slide and other play features Current Wald Park, with potential future conversion sites marked. 63

68 2016 Conceptual Rendering of Wald Park 64

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