Date: May 29, 2025
City of Chattanooga, Economic Development
101 E. 11th Street, Suite 200
Chattanooga, TN 37402
423-643-7330
These notices shall satisfy three separate but related procedural requirements for activities to be undertaken by the name of City of Chattanooga
FINAL 100-YEAR FLOODPLAIN NOTICE
This is to give notice that Universal Engineering Sciences, LLC (UES), on behalf of the City of Chattanooga (City), has conducted an environmental evaluation as required by Executive Order 11988, in accordance with HUD regulations at 24 CFR 55.20 Subpart C Procedures for Making Determinations on Floodplain Management, to determine the potential affect that its activity in the floodplain will have on the human environment for Housing Choice Voucher Program under V-971-00. The proposed Project is located at 315 Spears Avenue in Chattanooga, Hamilton County, Tennessee. The eastern edge of the Project site is within a Federal Flood Risk Management Standard (FFRMS) 100-year floodplain (Zone AE), encompassing approximately 0.03 acres in total. The extent of the FFRMS floodplain was determined using a freeboard value approach. The Council for Alcohol and Drug Abuse Services (CADAS), with the help of the City, HUD, Chattanooga Housing, Hamilton County, and the Tennessee Housing Development Agency plans to construct one, two story, 16-unit apartment building for drug and alcohol recovery services, on parcel 135F-E-002 along West Manning Street and Spears Avenue in Chattanooga, Tennessee (Project). This building establishes a permanent housing facility for people who have experienced homelessness, completed substance use disorder treatment and demonstrated at least two months of sobriety. The Project area covers approximately 0.21 acres and is completely urbanized with a parking lot making up all the Project site. Based on our review of available historical aerial imagery, the Project site has been a parking lot since 1983. Impacts on the floodplain are expected to be minimal, as the total number acres of floodplains within the Project site is approximately 0.03 acres. The floodplain is located in a heavily urbanized city setting, limiting the natural benefits of the floodplain for native flora and fauna.
The City has considered the following alternatives and mitigation measures to minimize adverse impacts and to restore and preserve natural and beneficial functions and intrinsic values of the existing floodplain. Multiple alternatives were considered, including an alternate Project site located across Spears Avenue, approximately 70 feet east of the proposed Project location; however, construction at this location would result in the entire project area being located within the FFRMS 100-year floodplain. Further, there is a permanent stormwater drain that cannot be altered due to a restrictive covenant, limiting CADAS’s ability to construct in the area. Thus, the alternate site was not chosen for development.
A No Action Alternative was also considered when reviewing sites for this project; however, this alternative was quickly rejected as these vulnerable residents are in need of housing for recovery. Housing for those in early recovery from substance use disorders is an acute challenge. DrugRehab.com reported in 2020 that some studies estimate about 40 percent of the [homeless population] is dependent on drugs or alcohol (Gonzales, 2020). Others say the figure is more than 50 percent. Several accounts even suggest drug use is twice as common among the homeless, per capita than among the general population. Many of these people have nowhere to turn for stable housing multiplied by their past behaviors, which have further limited their options. Thus, the need of the Project is to have safe, affordable housing for recovering citizens in the Chattanooga area. The No Action Alternative does not meet the needs of the City, thus, the No Action Alternative was not selected.
Mitigation measures have been implemented in order to minimize the effects of the flooding to limit the loss of life, property and preserving the natural values of the floodplain. In order to preserve lives, the local and county wide emergency broadcast system will implement an early warning system should flooding conditions arise. In addition to the warning system, law enforcement has an emergency evacuation and relocation plan. Emergency signage and evacuation route placards will be posted throughout the apartment complex, including a copy in each individual apartment. All residents will also be briefed on the location of the flood hazard area and evacuation plans upon placement in apartment. In order to preserve property, the CADAS apartments base floor will be built approximately 3 feet above the FFRMS freeboard elevation, this engineering control prevents loss of property due to flooding events. Further, flood insurance will be acquired and maintained in order to mitigate possible flood damage. As this Project includes non-loan forms of financial assistance, the property will be required to maintain flood insurance for the lifetime of the building, regardless of ownership. The natural value of the proposed Project site has been significantly reduced over the past decades of urbanization and development in the area; thus, the addition of the apartment complex is not expected to impact the natural value of the area. Though the site will consist of a majority of impervious surface, this is not a change from the site’s current conditions, as the Project site has been a parking lot since 1983.
The City has reevaluated alternatives to building in the floodplain and has determined that it has no practicable alternative to floodplain development. Environmental files documenting compliance with Executive Order 11988, as amended by Executive Order 13690, are available for public inspection, review and copying upon request at the times and location delineated in the last paragraph of this notice for receipt of comments.
There are three primary purposes for this notice. First, people who may be affected by activities in floodplain and those who have an interest in the protection of the natural environment should be given an opportunity to express their concerns and provide information about these areas. Second, an adequate public notice program can be an important public educational tool. The dissemination of information and request for public comment about floodplain can facilitate and enhance Federal efforts to reduce the risks and impacts associated with the occupancy and modification of these special areas. Third, as a matter of fairness, when the Federal government determines it will participate in actions taking place in floodplain it must inform those who may be put at greater or continued risk.
NOTICE OF FINDING OF NO SIGNIFICANT IMPACT AND NOTICE OF INTENT TO REQUEST RELEASE OF FUNDS
REQUEST FOR RELEASE OF FUNDS
On or about June 14, 2025 the City of Chattanooga will authorize the Council of Alcohol and Drug Abuse Services (CADAS) to submit a request to the U.S. Department of Housing and Urban Development (HUD) for the release of Project-Based Vouchers (PBV) funds under Title 24, Chapter IX, Part 983 of the Code of Federal Regulations-Housing Choice Voucher (HCV) Program, to undertake a project known as CADAS Phase 2 Apartments for the construction of 16 apartment units for sober living along Spears Avenue in Chattanooga, Tennessee, with anticipated funding of $2,750,000 (including non-HUD funding sources) at 315 Spears Avenue, Chattanooga, TN, 37405.
FINDING OF NO SIGNIFICANT IMPACT
The City of Chattanooga has determined that the project will have no significant impact on the human environment. Therefore, an Environmental Impact Statement under the National Environmental Policy Act of 1969 (NEPA) is not required. Additional project information is contained in the Environmental Review Record (ERR) on file at 101 E. 11th Street, Suite 200 Chattanooga, TN 37402 and may be examined or copied on weekdays from 8:00 AM to 4:30 PM EST and is also available for review via the following link: https://cpd.hud.gov/cpd-public/environmental-reviews.
PUBLIC COMMENTS
Any individual, group, or agency may submit written comments on the ERR to the City of Chattanooga, 101 E. 11th Street, Suite 200, Chattanooga, TN 37402. All comments received by June 13, 2025 will be considered by the City of Chattanooga prior to authorizing submission of a request for release of funds. Comments should specify which Notice they are addressing.
ENVIRONMENTAL CERTIFICATION
The City of Chattanooga certifies to HUD that Richard Beeland in his capacity as Administrator of Economic Development consents to accept the jurisdiction of the Federal Courts if an action is brought to enforce responsibilities in relation to the environmental review process and that these responsibilities have been satisfied. HUD’s approval of the certification satisfies its responsibilities under NEPA and related laws and authorities and allows the CADAS to use Program funds.
OBJECTIONS TO RELEASE OF FUNDS
HUD will accept objections to its release of fund and the City of Chattanooga’s certification for a period of fifteen days following the anticipated submission date or its actual receipt of the request (whichever is later) only if they are on one of the following bases: (a) the certification was not executed by the Certifying Officer of the City of Chattanooga; (b) the City of Chattanooga has omitted a step or failed to make a decision or finding required by HUD regulations at 24 CFR part 58; (c) the grant recipient or other participants in the development process have committed funds, incurred costs or undertaken activities not authorized by 24 CFR Part 58 before approval of a release of funds by HUD; or (d) another Federal agency acting pursuant to 40 CFR Part 1504 has submitted a written finding that the project is unsatisfactory from the standpoint of environmental quality. Objections must be prepared and submitted in accordance with the required procedures (24 CFR Part 58, Sec. 58.76) and shall be addressed to William Biggs, U.S. Department of Housing and Urban Development, Office of Public and Indian Housing, 701 Broadway, Suite 130, Nashville, TN 37203. Potential objectors should contact HUD to verify the actual last day of the objection period.