Final Notice and Public Explanation of a Proposed Activity in a Floodplain
To: All interested Government Agencies, Groups and Individuals
This provides notice that the City of Charleston as the Responsible Entity under Part 58 has conducted an evaluation as required by Executive Order 11988 & 13690, in accordance with HUD regulations at 24 CFR 55.20 Subpart C Procedures for Making Determinations on Floodplain Management and Wetlands Protection. The Sponsor is submitting this project under the HUD RAD Program, consisting of a RAD Conversion utilizing a RAD/Section 18 Blend for the disposition and rehabilitation of the existing multi-family apartment complex with no significant ground disturbing activities. The subject property, Kiawah Homes, is located at 2226 Sunnyside Avenue in Charleston, Charleston County, South Carolina and consists of thirty-one (31) single-story multi-family apartment structures and one (1) single-story community structure. The subject property structures were constructed in 1943 and are situated on 9.889 acres of land. The subject property is partially located in the Federal Flood Risk Management Standard (FFRMS) floodplain.
According to the Effective FEMA Flood Insurance Rate Maps (FIRMS) #45019C-0504K and #45019C-0512K, both dated January 29, 2021, the subject property is depicted within Unshaded Zone X, designated as an area outside the 100- and 500-year flood zones; Shaded Zone X, designated as an area within the 500-year floodplain; and Zone AE, designated as an area within the 100-year flood zone associated with the Ashley River, with a Base Flood Elevation of ten (10) feet. The Effective flood zone designations are confirmed on an ALTA/NSPS Land Title Survey prepared by Forsberg Engineering and Surveying, Inc. dated February 10, 2021. According to the FEMA Flood Map Service Center accessed at https://msc.fema.gov/portal/home, there are no preliminary or pending FIRMs for the subject property. No portion of the property is located within, or adjacent to, a regulatory floodway.
As the proposed undertaking involves a substantial rehabilitation of the property under the HUD RAD Program, it is subject to the regulations and requirements of the FFRMS Final Rule. Per the Federal Flood Standard Support Tool (FFSST) accessed at https://floodstandard.climate.gov/tool/, portions of the subject property are within the FFRMS floodplain per the Climate-Informed Science Approach (CISA), with an elevation of twelve (12) feet.
As proposed, minimal ground disturbance will occur within the floodplain due to rehabilitation activities which include exterior repairs such as the installation of a play area, a handicap compliant refuse and recycling collection area, accessible routes, and compliant curb ramps; the re-striping of the parking areas; the replacement of the sidewalks, four (4) structures’ porch columns/railings, roofing, gutters and downspouts, entry doors, windows, 75% of the exterior pad mounted A/C line sets, and the handrails/railings; the repair of the buildings foundations and siding; and the addition of striping and signage to the handicap parking area to ensure adequate van accessibility. HUD has considered alternatives and mitigation measures to be taken to minimize adverse impacts and to restore and preserve natural and beneficial values.
(i) The proposed action involves rehabilitation activities at an existing apartment complex that is located within an FFRMS floodplain. Per Elevation Certificates obtained for onsite buildings located in the FFRMS floodplain, all occupied residential spaces are all located above the FFRMS floodplain elevation. No structures or insurable property are located within a 100-year flood zone. Therefore, flood insurance is not required to be carried under the provisions of the NFIP.
(ii) The proposed action will not aggravate the current hazard to other floodplains nor disrupt floodplain values. The proposed rehabilitation activities within the FFRMS floodplain will have no impacts to the natural moderation of floods, water quality maintenance, or groundwater recharge, and do not create risks to lives or insurable property. No further means of avoiding activities within the floodplain are available.
(iii) The subject property is in need of rehabilitation activities to improve the quality of life of the tenants, to comply with modern regulations for safe housing options, and to improve the marketability of this existing multi-family apartment complex. The “No-Action” alternative would not achieve any of these benefits and thus, would not serve the same purpose.
The subject property does not represent a significant habitat or food resource for area wildlife or important plant species. In addition, the property does not represent a significant historic or recreational resource for area residents. Therefore, the proposed rehabilitation activities within the FFRMS floodplain do not represent a risk to lives and property or natural resources.
The Responsible Entity has reevaluated the alternatives to allowing disposition and rehabilitation under the HUD RAD Program for a property within the floodplain and has determined that it has no practicable alternative. Environmental files that document compliance with steps 3 through 6 of Executive Order 11988, 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.
This notice is being published to a) give those who have an interest in the protection of the natural environment and/or will be affected by development within a floodplain an opportunity to express their concerns and provide information about these areas; b) act as a public educational tool; and c) inform those who may be put at greater or continued risk by the Federal government’s participation in actions taking place in floodplains.
Written comments must be received by the Responsible Entity at the following address on or before September 12, 2024 (a minimum 7 calendar day comment period will begin the day after publication): Geona Shaw Johnson, Director, Department of Housing and Community, 75 Calhoun Street Suite 3200, Charleston, South Carolina 29401. A full description of the project may also be reviewed from 8:00 am to 4:30 pm at this address. Comments may also be submitted via email at hillk@charleston-sc.gov attention Kat Hill.
Date: September 5, 2024
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